HUGH, J. AULT
Comparative Income Taxation presents a comparative analysis of some of the most important structural and design issues which arise in income tax systems. In complex national income tax systems, structural and design variations from one country to another present major obstacles to the kind of comparative understanding that economic globalization requires. Hence the great significance of this outstanding book, highly acclaimed through three previous editions and now thoroughly updated to encompass the latest changes and trends. This edition addresses the absence of any consideration of the issues from the perspective of developing countries with emerging economies. In this book, leading authorities from eleven of the world's most important national taxation systems each contribute their particular expertise to a study of specific crucial problems of tax design. In addition to the nine countries covered in previous editions-Australia, Canada, France, Germany, Japan, the Netherlands, Sweden, the United Kingdom and the United States-China and India have now been added to provide the perspective of developing countries.
What's in this book:
Individually authored country descriptions outline the climate and institutional framework in which each of the eleven national taxation systems' substantive rules operate. All the country descriptions are analyzed in accordance with a common format to facilitate comparisons of the ways in which the countries' tax systems are similar and in which they differ. They form the background to an expertly informed comparative analysis focusing on three major areas: basic income taxation, taxation of business organizations and international taxation. Most of the rules that are especially important for international business and investment are dealt with here, including (among many others) rules on the following:
classification of business entities;
taxation of corporations and their shareholders;
corporate organization and restructuring;
taxation of partnerships;
residence and source taxation;
controlled foreign company rules;
restrictions on the deduction of interest;
courts dealing with tax matters; and
effect of tax treaties.
Several new topics-including the classification of employees and independent contractors, the taxation of pensions, patent box regimes, the taxation of indirect transfers and the tax challenges of the digital economy-have been added. Especially timely are discussions of changes stemming from the G20/OECD Base Erosion and Profit Shifting project. The introduction has also been expanded to include a new section on the European Union (EU) law as it affects the tax laws of EU Member States.
How this will help you:
Since the publication of the first edition in 1997, this fourth edition will be a classic source of information and analysis for students, professors, researchers, tax practitioners and tax policy officials on the different ways that countries design their income tax systems. This book with fresh insights and perspectives will be widely welcomed by the international tax community.
Principal Authors
Contributing Authors
Foreword
Preface
List of Abbreviations
Introduction
An Introduction to European Tax Law
PART I
General Description
Australia
Richard Vann & Graeme S. Cooper
Canada
Brian J. Arnold
China
Jinyan Li
France
Guy Gest
Germany
Christine Osterloh-Konrad & Wolfgang Schön
India
D.P. Sengupta
Japan
Minoru Nakazato, Mark Ramseyer, Takeshi Fujitani & Yasutaka Nishikori
The Netherlands
Kees van Raad & Frank Pötgens
Sweden
Peter Melz & Jérôme Monsenego
The United Kingdom
Glen Loutzenhiser
The United States
James R. Repetti & Diane M. Ring
PART II
Basic Income Taxation
SUBPART A
Global Versus Schedular Design of Income Tax
SUBPART B
Inclusions in the Tax Base
SUBPART C
Deductions
SUBPART D
Accounting
SUBPART E
Attribution of Income
PART III
Taxation of Business Organizations
SUBPART A
Corporate-Shareholder Taxation
SUBPART B
Partnership Taxation
PART IV
International Taxation
SUBPART A
Residence Taxation
SUBPART B
Source Taxation
SUBPART C
Additional International Topics
Index
