International Tax - The Fundamentals

Examine how individuals are taxed, from personal income tax with employer withholding to self-employment and investment income. Understand how residency, citizenship, territorial, and source-based bases determine a country's tax rights.

Explore residency, citizenship, and territorial tax bases and the source basis, and how they tax worldwide or local income, with examples from Spain, the United States, and Malaysia.

Discover how your tax presence is determined by tax residency and income sources, including territorial and citizenship-based systems, and learn how double taxation and treaties affect filings.

Use the 183 days rule and other residency tests to determine tax residency for individuals, tracking days, home, and economic ties, and understand double tax treaties.

Explore how companies are taxed internationally by identifying tax residence as the country of incorporation and examining factors like central management and control, permanent establishment, and controlled foreign company rules.

central management and control determines tax residency by where the board of directors and top executives make strategic decisions, not merely the country of incorporation.

Explore how permanent establishment rules tax a foreign enterprise's profits tied to activities in a country via fixed places of business (branches, offices, factories) and dependent agents, with duration criteria.

CFC rules attribute income of foreign subsidiaries to the domestic parent to deter tax avoidance. They use ownership thresholds and a tax rate test targeting passive income.

Understand how tax havens and management rules, including P and CFC rules, can create tax liabilities across borders, and how double tax treaties address cross-border taxation.

Explore how double tax treaties rely on OECD and UN models to promote uniformity, detailing structure, provisions, and exemption and credit methods to avoid double taxation.

Learn a three-step approach to double tax treaties in international tax fundamentals: check local law, determine treaty residency with article four, and apply exemption or credit for specific income.

this case study shows dual US–Thailand residency resolved by the permanent home test, with government service pensions taxed in the US and a tax credit to avoid double taxation.

Explore how a Dubai company managed from Bali raises residency and double taxation issues under a UAE–Indonesia treaty, using place of management and tax credits.

Double tax treaties allocate taxing rights between countries and override local law to prevent double taxation. They cannot create a tax charge and only mitigate taxes, with residency determining applicability.

Explore consumption taxes, such as sales tax, value added tax, and GST, which apply to spending rather than profits. Customer location determines the tax, and the company collects it.

Explore how sales tax functions as a direct tax on goods and services, collected at point of sale and remitted to the government, with varying rates by state and locality.

Learn how value added tax, collected at every stage of production, operates in the UK and EU. Businesses charge and deduct VAT, while the end customer bears the tax.

Explore goods and services tax, a value-added tax applied at each production and distribution stage, where businesses collect and remit gst and the customer bears the tax.

Identify customer locations, what you sell, and thresholds triggering VAT, GST, or sales tax across jurisdictions. Track these details with an up-to-date system and platform tools to stay compliant.

Businesses collect consumption taxes to relieve individuals from yearly reporting and must monitor customers worldwide to apply location-specific rules and thresholds for compliance.

Analyze tax havens and offshore banking, defined by low taxes, financial secrecy, and easy incorporation, and examine OECD and EU criteria, BEPS, CRS, and substance regulations.

Explore offshore banking, its link to tax havens, and legitimate uses like diversification and asset protection, while noting risks of tax evasion, money laundering, and transparency through FATCA and CRS.

Explore how tax havens offer low taxes, banking secrecy, with minimum taxes and OECD-led changes flattening advantages, ending offshore evasion while retaining usefulness for asset protection and doing business.

Learn how to plan an efficient international tax strategy that keeps you compliant while optimizing tax efficiency, focusing on transfer pricing and holding company structuring.

Explore transfer pricing across global subsidiaries using the arm's length principle. Apply five methods—comparable uncontrolled price, resale price, cost plus, TNMM, and profit split—with benchmarks and case examples.

Understand how holding companies enable consolidated ownership of operating entities, streamline governance, and reduce withholding taxes on dividends while leveraging favorable capital gains treatment in tax-friendly jurisdictions like Singapore.

Explore personal residency planning to minimize tax by selecting zero or low income tax countries. Learn to avoid tax residency elsewhere, check leaving-country rules, and understand non-tax consequences.

Understand how residency and source-based taxation shape personal investment planning, including rental income and gains, with examples of no capital gains tax in Singapore, Hong Kong, Malaysia, UAE, and Bermuda.

Explore how to legally reduce taxes through forward planning, including transfer pricing, holding company structuring, and optimizing personal tax residency, investment income, and capital gains, while complying with changing laws.

Examine Apple's cost sharing with Irish subsidiaries, transferring IP rights and co-funding US R&D to shift profits to Ireland’s 12.5% rate; reveal EU investigations, stateless entities, and BEPS reforms.

Analyze how Starbucks used transfer pricing, royalties to the Netherlands, intercompany loans, and cross-border bean purchases to suppress UK profits, provoking public scrutiny and BEPS reforms.

Explore how Google, Amazon, Facebook, Nike, and Microsoft route intellectual property to Ireland, Luxembourg, and other jurisdictions to minimize corporate taxes, with notable transfer pricing cases and settlements.

Explore how the 183-day rule defines tax residency in Spain, why worldwide income is taxed, and how documentation influenced Shakira's settlement and fines.

Explore how high-profile figures navigate tax residency and citizenship to optimize tax exposure, including moves to Monaco and Florida and offshore image rights arrangements.

Navigate key international tax concepts from residency and source of income to corporate residency, transfer pricing, and double tax treaties, including consumption taxes and global transparency rules.