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International Taxation of Manufacturing and Distribution by John Abrahamson

International Taxation of Manufacturing and Distribution

By John Abrahamson


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Series on International Taxation Volume 56

International Taxation of Manufacturing and Distribution introduces and analyses the international tax issues which relate to international manufacturing and distribution activities - extending from the tax regime in the country where the manufacturing activities are located, through regional purchase and sales companies - to the taxation of local country sales companies. The analysis includes looking at domestic tax laws related to manufacturing and distribution company profits, as well as international tax issues related to income flows and payment of dividends. The book has a broad scope, covering similar issues such as customs tariffs, VAT, contract manufacturing and tolling, group treasury, withholding taxes, mergers and acquisitions, asset finance and leasing, derivatives, and related transfer pricing issues.

What’s in this book

Among the topics and issues analysed are the following:

  • foreign tax credits;
  • taxation in the digital economy;
  • tax incentives for export and investment;
  • intellectual property;
  • group treasury companies;
  • controlled foreign corporation provisions;
  • free trade agreements and customs unions;
  • transfer pricing;
  • role of tax treaties;
  • hedging;
  • related accounting issues;
  • deferred tax assets and liabilities;
  • tax risk management;
  • supply chain management;
  • depreciation allowances; and
  • carry-forward tax losses.

The book includes descriptions of twenty-one country tax systems and ten detailed case studies as specific examples for the analysis. Up-to-date and detailed attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. The most important portions of the OECD Model Tax Convention, the United Nations Model Tax Convention, the North American Free Trade Agreement, and the EU Union Customs Code are presented in appendices. The content of this book clearly identifies and explains the management of research and development and intellectual property used in manufacturing as well as the structures used in mergers and acquisitions, group treasury operations, and transfer pricing issues for manufacturing groups.

How this will help you

International Taxation of Manufacturing and Distribution provides the most thorough treatment of its subject available. As a full-scale commentary and analysis of international taxation issues relating to multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It serves as a springboard for problem solving by providing case studies (including answers) and acts as an aid to practitioners in mastering international taxation issues concerning global manufacturing and distribution. It is, therefore, of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.

Pages 496
Last Updated 02/18/2016
Update Frequency As Needed
Product Line Kluwer Law International
ISBN 9789041166647
SKU 10059263-0001
Table of Contents


List of Abbreviations

CHAPTER 1 Introduction

CHAPTER 2 Overview of International Taxation

CHAPTER 3 Examples of Country Tax Systems

CHAPTER 4 Manufacturing

CHAPTER 5 Procurement Companies

CHAPTER 6 Distribution and Regional Sales Companies

CHAPTER 7 Shipping and Air Transport

CHAPTER 8 Value Added Tax

CHAPTER 9 Customs Duties and Tariffs

CHAPTER 10 The Digital Economy

CHAPTER 11 Social Security Taxes

CHAPTER 12 Tax Incentives

CHAPTER 13 Taxation Issues for Dividends and Profit Distributions

CHAPTER 14 Taxation Issues for Funding and Interest Flows

CHAPTER 15 Group Restructures and Taxation Issues for Capital Gains

CHAPTER 16 R&D and Intellectual Property

CHAPTER 17 Treasury and In-House Banking Companies

CHAPTER 18 Group Insurance Companies: Captive Insurance

CHAPTER 19 Taxation Issues for Mergers and Acquisitions

CHAPTER 20 Acquisitions and Sale and Purchase Agreements

CHAPTER 21 Tax Due Diligence for Mergers and Acquisitions

CHAPTER 22 Asset Leasing

CHAPTER 23 Derivatives: Options, Forwards and Swaps

CHAPTER 24 Interest Deductions in Subsidiaries and Thin Capitalisation

CHAPTER 25 Tax Havens and Controlled Foreign Corporations Rule

CHAPTER 26 Introduction to Transfer Pricing

CHAPTER 27 Transfer Pricing Issues for Manufacturing and Distribution

CHAPTER 28 Intangibles and Transfer Pricing

CHAPTER 29 Intra-group Services and Transfer Pricing

CHAPTER 30 Loan Financing, Interest Payments and Transfer Pricing

CHAPTER 31 General Conclusions


CASE STUDY 1 International Tax Issues: Investing into Malaysia

CASE STUDY 2 Permanent Establishments and Sales Activities

CASE STUDY 3 Tax Residence and Domestic Tax Law

CASE STUDY 4 Permanent Establishments and Manufacturing

CASE STUDY 5 Repatriating Profits: Tax Treaties and Domestic Tax Laws

CASE STUDY 6 Asset Acquisitions and Mergers and Acquisitions Planning

CASE STUDY 7 Analysis of Due Diligence Reports for Mergers and Acquisitions

CASE STUDY 8 Group Funding and Treasury Structures

CASE STUDY 9 Manufacturing, Distribution and Group Transfer Pricing

CASE STUDY 10 Group Intellectual Property and Transfer Pricing


APPENDIX I OECD Model Tax Convention 2014 – Condensed Version

APPENDIX II North American Free Trade Agreement (NAFTA) – Summary

APPENDIX III North American Free Trade Agreement (NAFTA) – Summary of Terms

APPENDIX IV North America Free Trade Agreement (NAFTA) – Extracts

APPENDIX V European Union – Union Customs Code

APPENDIX VI European Union – Union Customs Code

Table of Cases

Table of Statutes and Directives

Table of Treaties and International Agreements