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Publication of 'International Taxation - Theory and Practice'
Altus Alliance member spotlight: Sakura Shiga
In 2009, Altus Alliance - Japan member Sakura Shiga co-authored and edited a chapter on International Taxation in the book “Tax Aspects of Legal Dispute Resolution”. Expanding upon this earlier writing, Shiga-san has now published 'International Taxation - Theory and Practice' through publisher Minjihou-Kenkyuukai. As a specialist in Transfer Pricing, Shiga-san has dedicated an entire chapter to the topic, with it and other international taxation issues discussed in the following chapters:
- Introduction
- Domestic Laws and Regulations
- Tax Treaties
- Prescriptive Jurisdiction
- Transfer Pricing
- Controlled Foreign Company
- Thin Capitalisation
- Cross Border Financial Transactions
- Globalisation, IT, National ID and International Taxation
Sub-topics in 'International Taxation - Theory and Practice' include:
- The Latest Supreme Court Decision in relation to OECD Model Convention
- Look Through Entities
- Conflict of Laws
- OECD Committee on Fiscal Affairs
- E-Commerce, Service PE
- "Attribution of Profits to PE" of 2008
- Treaty Shopping and LOB Clause
- OECD Model Tax Information Exchange Agreement
- Fable and Fallacy of Transfer Pricing
- Technical Concepts of Transfer Pricing
- Source Taxation and Cross Border Financial Transactions
- National ID Number System in Sweden
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