Preface
CHAPTER 1
Introduction
CHAPTER 2
Overview of International Taxation and OECD BEPS Measures
CHAPTER 3
Tax Treaty Provisions
CHAPTER 4
Examples of Country Fiscal Systems
CHAPTER 5
Upstream Oil and Gas Taxation: Exploration and Production
CHAPTER 6
Tankers and Bulk Carriers
CHAPTER 7
Pipelines
CHAPTER 8
Downstream Taxation: Refineries and Processing Plants
CHAPTER 9
Coal Exploration and Production
CHAPTER 10
Power Stations and Electricity Networks
CHAPTER 11
Renewable Energy: Supply, Funding, and Taxation Incentives
CHAPTER 12
Carbon Taxes and Emissions Trading Schemes
CHAPTER 13
Contractor Services and Permanent Establishments (PEs)
CHAPTER 14
Value Added Tax
CHAPTER 15
Customs Duties and Tariffs
CHAPTER 16
Holding Companies, Dividends, and Profit Distributions
CHAPTER 17
Interest Deductions in Subsidiaries and Thin Capitalisation
CHAPTER 18
Interest Flows and Hybrid Arrangements
CHAPTER 19
Capital Gains, Group Restructures, and Private Equity
CHAPTER 20
Group Procurement Companies
CHAPTER 21
Group Marketing Companies
CHAPTER 22
Group R&D and Intangible Property Companies
CHAPTER 23
Group Treasury and In-House Banking Companies
CHAPTER 24
Group Service Companies
CHAPTER 25
Group Insurance Companies
CHAPTER 26
Mergers and Acquisitions
CHAPTER 27
Asset Leasing
CHAPTER 28
Tax Havens and Controlled Foreign Corporations Rules
CHAPTER 29
Introduction to Transfer Pricing
CHAPTER 30
Transfer Pricing Issues for Energy Production and Distribution
CHAPTER 31
Intangibles and Transfer Pricing
CHAPTER 32
Intra-group Services, Cost Contribution Arrangements, and Transfer Pricing
CHAPTER 33
Loan Financing, Interest Payments, and Transfer Pricing
CHAPTER 34
OECD BEPS and the Changing Tax Environment
CHAPTER 35
Design of Energy Fiscal Systems
CHAPTER 36
General Conclusions
Case Studies
CASE STUDY 1
Renewable Energy: The Offshore Wind Farm Project, Income Flows, and Permanent Establishments (PE)
CASE STUDY 2
Upstream Oil and Gas: The New Production Sharing Contract (PSC)
CASE STUDY 3
Treasury and Finance: The Group Treasury Centre, Loans, and Derivatives
CASE STUDY 4
Mergers and Acquisition: Private Equity Sale of an Electricity Transmission Network
CASE STUDY 5
Group Research and Development (R&D): Cost Contribution Arrangements (CCA)
CASE STUDY 6
Group Technology: The New Battery Storage System and Tax Treaties
CASE STUDY 7
Group Technology: The Solar Power Station, Transfer Pricing, and Mutual Agreement Procedures (MAP)
CASE STUDY 8
Group Marketing: The Liquefied Natural Gas (LNG) Marketing
Appendices
APPENDIX I
OECD Model Tax Convention 2017: Condensed Version
APPENDIX II
North America Free Trade Agreement (NAFTA): Extracts
APPENDIX III
European Union: Union Customs Code
APPENDIX IV
European Union: Union Customs Code
Table of Cases
Table of Statutes and Directives
Table of Treaties and International Agreements
Index
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