The General Report And The Branch Reports Discuss The Tax Treatment Of (mainly) Cross-border Interest Payments For Borrowers And Lenders. It Encompasses The Various Means By Which A Corporation (borrower) Based In One Jurisdiction Finances Its Domestic And Foreign (business) Activities And The Various Means By Which Another Corporation (lender) Funds Business Activities In Another Juristiction General Reporter, Pascal Hinny ; Discussion Leader, Brian J. Arnold. Subject 2. 62nd Congress Of The International Fiscal Association, Brussels, 2008–half T.p. Includes Bibliographical References.
Dive deep into the intricate world of international corporate finance with "2008 Cahiers de Droit Fiscal International, Volume 93b," a cornerstone publication from the International Fiscal Association (IFA). This comprehensive volume, stemming from the 62nd IFA Congress held in Brussels in 2008, meticulously examines the tax treatment of cross-border interest payments, a critical aspect of global business operations. At the heart of this volume lies an in-depth exploration of how multinational corporations navigate the complex tax landscapes when financing their activities across borders. Subject 2 of the Congress, expertly led by General Reporter Pascal Hinny and Discussion Leader Brian J. Arnold, focuses specifically on the mechanisms corporations use to fund both domestic and foreign ventures. This includes a thorough analysis of the strategies borrowers (corporations seeking capital) and lenders (corporations providing capital) employ across different jurisdictions. Understanding these mechanisms is crucial for tax professionals, lawyers, academics, and anyone involved in international finance. "2008 Cahiers de Droit Fiscal International, Volume 93b" sheds light on the various tax implications and challenges associated with cross-border interest payments, offering valuable insights into potential tax planning strategies and compliance requirements. The book delves into various funding methods utilized by corporations, analyzing how tax laws in different countries impact the overall cost and efficiency of cross-border financing. It addresses critical questions such as: * How are interest payments treated under different tax treaties? * What are the transfer pricing considerations when determining interest rates for related-party loans? * How do thin capitalization rules affect the deductibility of interest expenses? * What are the potential tax risks associated with cross-border financing structures? This volume is not just a collection of reports; it represents a collaborative effort from leading tax experts worldwide. The branch reports provide diverse perspectives on the subject, reflecting the nuances and complexities of tax systems in various jurisdictions. The general report synthesizes these viewpoints, offering a cohesive and insightful overview of the key issues and challenges. Containing 808 pages, this perfect paperback is a substantial resource, filled with detailed analysis, case studies, and bibliographical references to further enrich your understanding. While focusing on the landscape of 2008, the fundamental principles and considerations discussed in "2008 Cahiers de Droit Fiscal International, Volume 93b" remain highly relevant in today's evolving global economy. It offers a deep and enduring resource for understanding the tax implications of international financing. Add this significant volume to your collection and gain a deeper understanding of cross-border tax strategies.