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Product Line
Kluwer Law International
ISBN-13
9789403523194
Availability
Ships in 5-7 Business Days
Last Updated
2025-11-04

Overview

Taxation of Trusts, Foundations and Similar Arrangements in a Global Setting is an exceptional book that offers practitioners extensive global coverage of direct taxation of trusts and foundations, wealth taxes, procedural matters, philanthropy, and international tax planning. One of the most complex areas of tax practice concerns the interwoven area of trusts, foundations and similar arrangements, particularly when an international element is involved.


What’s in this book:

Eminent authors and practitioners have contributed to this compendium offering both theoretical and practical perspectives. This edited volume provides clear and accessible guidance on the following taxation issues and topics: 


  • trusts and private international law;
  • trends in domestic taxation of trust and foundations worldwide;
  • trusts and abuse in a domestic law context;
  • tax treaty interpretation issues;
  • special tax cooperation agreements;
  • trusts and value-added tax;
  • effect of the proposed Business in Europe Framework for Income Taxation (BEFIT) Directive;
  • flow-through entities and the OECD Pillar Two;
  • transfer pricing issues;
  • philanthropic holding foundations; and
  • special focus on jurisdictions unfamiliar with trusts and foundations.

How this will help you:

Tax lawyers and other tax professionals will gain a comprehensive understanding of how trusts and foundations are taxed across different jurisdictions and confidently navigate complex taxation issues, including often-overlooked and cross-border aspects. The essential insights of this book will also prove invaluable to academic research, policy development, and practical tax decision-making in a globalized environment.

Table Of Contents

Editors


Contributors


PART I

Non-tax Approach to Trusts and Similar Arrangements


CHAPTER 1

Trust and Private International Law: Critical Analysis

Javier Carrascosa González


CHAPTER 2

Is Private Law Crucial When Dealing with the Taxation of Trusts? The Law of Trusts for Civilian (Tax) Lawyers

Andrés Báez Moreno & Svetislav V. Kostic


PART II

Tax Treatment of Trusts and Foundations under Domestic Law


CHAPTER 3

Trends in Common Law Countries in the Tax Treatment of Trusts

Mark Brabazon


CHAPTER 4

Trends in Taxation of Foundations

Marcel R. Jung


CHAPTER 5

Trusts and Abuses in the Context of Domestic Law

Álvaro de la Cueva & Carmen Carmona


PART III

Tax Treaty Issues with Trusts, Foundations and Similar Arrangements


CHAPTER 6

Tax Treaty Interpretation Issues Relating to Trusts, Foundations, Similar Arrangements

Mario Tenore


CHAPTER 7

Tax Treaty Conflicts in Relation to Attributing Trust Income and the Vexed Issue of Beneficial Ownership as It Relates to Trusts

Michael McGowan


CHAPTER 8

Trust and Tax Treaty Abuse

Stefano Loconte


CHAPTER 9

International Taxation of Foundations and Trusts According to Special Tax Cooperation Agreements: The Tax Agreement Between Liechtenstein and Austria

Martin Wenz, Niklas Kaiser & Ramona Lässer


PART IV

Specific Challenges of Trusts and Similar Arrangements for Transaction and Wealth Tax Purposes


CHAPTER 10

Trusts and Taxes on Wealth

Violeta Ruiz Almendral


CHAPTER 11

Wealth Taxes and Wealth Planning: The Role of Foundations

Peter Hongler & Subiksha Thirumamany


CHAPTER 12

Trusts and Value Added Tax

Karoline Spies & Dominic Krenn


PART V

Trusts and Foundations: EU Tax Law Implications


CHAPTER 13

Trusts, Foundations and Similar Arrangements and the EU Fundamental Freedoms

Moritz Scherleitner & Rita Szudoczky


CHAPTER 14

The Impact of the EU Public CbCR Directive and the Proposed BEFIT Directive on Trusts, Foundations and Similar Arrangements

Jean-Philippe Van West


PART VI

Impact of Pillar Two and Recent EU Corporate Tax Initiatives on Trusts, Foundations and Similar Arrangements


CHAPTER 15

Impact of Pillar Two Scoping Rules on Trusts, Foundations and Similar Arrangements

Kinga Romanovska


CHAPTER 16

Flow-Through Entities and the OECD Pillar Two

Leopoldo Parada


CHAPTER 17

Transfer Pricing Issues When Dealing with Trusts, Foundations, and Similar Arrangements

Amanda Pletz & Ayushi Rungta


PART VII

Trusts, Foundations and Other Similar Arrangements for Philanthropic Purposes


CHAPTER 18

Philanthropic Holding Foundations: Reassessing a Tax Definition of Philanthropy

Giedre Lideikyte Huber


CHAPTER 19

Under What Circumstances Can Stewardship Foundation Structuring Be a Solution to Families, Enterprises and Society at Large?

Ineke A. Koele


CHAPTER 20

Enterprise Foundations: Choosing the Right Purpose

Mark Ørberg & Søren Friis Hansen


Index

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Taxation of Trusts, Foundations and Similar Arrangements in a Global Setting | Wolters Kluwer Legal & Regulatory