Corporate Residence and International Taxation

Book overview

The book delves into the intricate concept of corporate residence, its evolution in the United Kingdom's case law, and its contemporary applications in income tax conventions and Canadian domestic tax regulations.

Key themes and topics

The foundation of the international tax system rests upon the distinction between residence and source taxation. Yet, when it comes to the taxation of incorporated companies across many countries, the concept of residence taxation, particularly regarding issues like double taxation, has always posed both policy and practical challenges within various tax systems. This comprehensive volume delves into the intricacies of corporate residence, examining its evolution through the lens of English case law, its alignment with the OECD Model residence definition, and its integration into domestic statutory provisions.

The primary objective of this book is to uncover the essence of corporate residence, shedding light on its historical development within the United Kingdom, and its contemporary applications in income tax treaties and Canadian domestic income tax law. Furthermore, the book explores the delicate balance between tax compliance and tax avoidance strategies employed by multinational corporations. It analyses how the concept of residence can be manipulated to reduce taxable income and explores the role of foreign tax credit in mitigating double taxation within the framework of international tax treaties.