Introduction
Overview of international taxation
Examples of country tax systems
Manufacturing
Procurement companies
Distribution and regional sales companies
Shipping and air transport
Value added tax
Customs duties and tariffs
The digital economy
Social security taxes
Tax incentives
taxation issues for dividends and profit distributions
Taxation issues for funding and interest flows
Group restructures and taxation issues for capital gains
R&D and intellectual property
Treasury and in-house banking companies
Group insurance companies: captive insurance
Taxation issues for mergers and acquisitions
Acquisitions and sale and purchase agreements
Tax due diligence for mergers and acquisitions
Asset leasing
Derivatives: options, forwards and swaps
Interest deductions in subsidiaries and thin capitalism
Tax havens and controlled foreign corporations rules
Introduction to transfer pricing
Transfer pricing issues for manufacturing and distribution
Intangibles and transfer pricing
Intra-group services and transfer pricing
Loan financing, interest payments and transfer pricing
General Conclusions
Case studies
Appendices.