International taxation of energy production and distribution

Introduction -- Overview of international taxation and OECD BEPS measures -- Tax treaty provisions -- Examples of country fiscal systems -- Upstream oil and gas taxation: exploration and production -- Tankers and bulk carriers -- Pipelines -- Downstream taxation: refineries and processing plants -- Coal exploration and production -- Power stations and electricity networks -- Renewable energy: supply, funding, and taxation incentives -- Carbon taxes and emissions trading schemes -- Contractor services and permanent establishments (PEs) -- Value added tax -- Customs duties and tariffs -- Holding companies, dividends, and profit distributions -- Interest deductions in subsidaries and thin capitalisation -- Interest flows and hybrid arrangements -- Capital gains, group restructures, and private equity -- Group procurement companies -- Group marketing companies -- Group R & D and intangible property companies -- Group treasury and in-house banking companies -- Group service companies -- Group insurance companies -- Mergers and acquisitions -- Asset leasing -- Tax havens and controlled foreign corporations rules -- Introduction to transfer pricing -- Transfer pricing issues for energy production and distribution -- Intangibles and transfer pricing -- Intra-group services, cost contribution arrangements, and transfer pricing -- Loan financing, interest payments, and transfer pricing -- OECD BEPS and the changing tax environment -- Design of energy fiscal systems -- General conclusions.

"Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provide in this timely and practical book. Taking a down-to-earth, problem-solving approach to policy and practice in the field worldwide, the author focuses on the international tax framework, and the tax regimes in leading energy producing and consuming countries." Provided by publisher.