International Commercial Transactions

Building a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms.

Thinking about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about commercial tax issues.

• Conceptual structure focusing on generic tax issues and their solutions aids understanding and facilitates cross-border comparison to highlight peculiarities of particular rules

• Domestic, treaty and European Council rules are discussed with respect to particular tax issues, facilitating an holistic approach to tax issues, much as is faced in practice

• Links topics and types of laws with a discussion of how they interact, aiding understanding and encouraging lateral thinking

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