Boek
International Taxation of Cross-Border Leasing Income focuses on the practical aspects of one of the most practiced and highly effective techniques of asset financing, ie, cross-border leasing. Globally, over the past few decades, the volumes as well as complexity of the leasing transactions have grown steadily. In addition, a variety of transaction formats has evolved in various jurisdictions as a result of the continuous legislative amendments on the one hand and innovative transaction structures developed by the financial services industry on the other hand. International Taxation of Cross-Border Leasing Income discusses the practical issues faced by the banks, financial institutions, companies engaging in leasing as a form of asset financing, and their tax advisers. The book elaborately deals with the divergent tax treatment in the five most important leasing jurisdictions (ie, US, Japan, Germany, UK and Netherlands) in respect of transaction characterization, depreciation, income-recognition and anti-avoidance rules, as well as divergence in the relevant bilateral tax treaty provisions. Further, the book investigates how the parties to a cross-border leasing transaction may obtain tax advantages due to such divergent tax treatments, and whether and to what extent the general or specific anti-avoidance rules in the jurisdictions may neutralize the tax arbitrage opportunities. Finally, it examines how the framework of the EC Treaty may be relevant for cross-border leasing transactions between the EC Member States.This book is of interest to practitioners active in cross-border leasing, while academics will benefit from its theoretical insights. «
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