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Book Review

 
George Gillham McGrigors reviews Fundamentals of International Tax Planning edited by Raffaele Russo; Published by IBFD; 266 pp; ISBN: 978-90-8722-017-7; 120 Euros
 
This text identifies a number of key background issues that feed into the fundamentals of international tax planning. It is worth setting them out to understand the context in which the book is written.
 
Most modern multinational enterprises are run as corporate groups. In them business policies and strategies are usually set by the board of directors of the ultimate parent. Thus in practice the companies within the group will operate as a single enterprise. The separate legal entities forming the group will be a business fiction to a large extent.
 
In most states corporate profit taxation is based on two fundamental principles: the company-by-company...

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