International Taxation of Manufacturing and Distribution

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.

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.

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.

Features:

• Introduces and analyses international tax issues for manufacturing and distribution.
• Includes examples of country tax regimes.
• Analyses manufacturing tax issues including tax incentives for export and investment.
• Analyses permanent establishment issues relating to contract manufacturing and tolling structures, VAT and customs duties.
• Explains international tax issues relating to interest and dividend flows, capital gains, and foreign tax credits and the related tax treaty issues.
• Explains the management of research and development and intellectual property used in manufacturing.
• Identifies and explains the structures used in mergers and acquisitions, group treasury operations, and transfer pricing issues for manufacturing groups.

Benefits:

• An essential guide for tax accountants, lawyers, economists, financial managers and government officials.
• Understand the structures used by multinational manufacturing groups.
• Practice problem solving with case studies and included answers.
• Master the international taxation issues of global manufacturing and distribution.