International Tax Handbook - ITH2

Introduction: scope of International Tax Handbook

This book looks at tax planning by multinationals, both United Kingdom and foreign controlled, in the context of the development of United Kingdom tax law including Double Taxation Agreements, and with some reference to the tax law of other countries. It is intended to provide an introduction to the subject viewed in the perspective of this Department's interest. Consistent with that objective it is a short book, short certainly by comparison with many which have appeared in the extensive literature on the subject in recent years.

The book is concerned primarily with the corporate sector. But, because the law for individuals and companies was virtually the same until the introduction of Corporation Tax in 1965 and Corporation Tax itself derives substantially from Income Tax, what is said in some chapters, particularly on partnerships and on the liability of non-residents, is also relevant to individuals. The legislation directed at tax planning in the international area by individuals - ICTA88/S739 - is not included. The approach of that legislation is significantly different from that designed for the corporate area and its administration is, for good reason, different too. It is operated by a specialist section, though Districts are asked to report likely cases (IM4622). Likewise avoidance by trusts is not covered. But in the corporate area, although International Division gives a lead and will take over some cases, Districts have to get closely involved and so this book concentrates on companies.