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Fundamentals of International Tax Planning

This book examines the tools currently used by multinational enterprises to benefit from the opportunities and overcome the problems created by the global economic market.

Fundamentals of International Tax Planning

Raffaele Russo
Date of publication:


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Print Book

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Fundamentals of International Tax Planning

Why this book

Economic activities have never been as global as they are today. This has contributed to the increase in the mobility of economic activities around the globe and has created opportunities – as well as problems – for the players in the world economy.
Looking at this setting from a tax perspective, Fundamentals of International Tax Planning provides readers with a basic knowledge of the tools currently used by multinational enterprises to benefit from the opportunities and overcome the problems created by the expansion of the market.
In other words, this book looks at techniques used to reduce an MNE’s tax burden. Planning techniques are described in a neutral and concise manner, without taking into account a specific jurisdiction, but based on the principles that underlie them.



  • Sources of international tax law, such as domestic and international legislation in this area.
  • Building blocks of international tax planning: arm’s length principle and permanent establishment.
  • The differences between the concepts of tax planning, avoidance and evasion.
  • Categorization of planning techniques based on their underlying principles
  • The structure and goals of a multinational group, with particular emphasis on taxation.
  • Tax planning techniques that can be used to effectively carry out activities such as holding, financing, hedging and IP management.
  • Supply-chain management techniques and how taxes come into play when (re-)organizing them
  • General and specific anti-avoidance rules that have from time to time been designed by States in order to counteract behaviours and structures that are not considered acceptable from a tax policy point of view.



Chris J. Finnerty is an International Tax Partner in the National Tax Services practice of Ernst & Young LLP. Currently based in Shanghai, China, Chris is responsible for the leadership of the ITS tax desk group for Greater China, serving multinationals investing into China, and the region, as well as Hong Kong and China based companies investing abroad. He has extensive experience in international M&A and designing and implementing comprehensive integrated solutions that optimize the tax position of US multinationals. In that capacity, Chris has provided international tax consulting services to numerous global companies over the past 19 years and has significant experience in design, development, and implementation of global holding companies, tax efficient financing, cash repatriation and redeployment structures, and global income migration. Chris is a frequent speaker and lecturer at firm sponsored global events and various tax organizations in the U.S. and internationally, including the Tax Executives Institute and the International Tax Academy of the IBFD.
Paulus Merks obtained a degree in Dutch tax law from the University of Amsterdam and an LL.M. in US taxation from the University of San Francisco. After assignments for Ernst & Young toin New York, Paris, Chicago and San Jose (California), Paulus returned to the Ernst & Young Amsterdam office where he advises clients on a broad range of domestic and international tax issues in connection with mergers and acquisitions, reorganizations, initial public offerings, financial transactions and financial instruments.
Mario Petriccione is a Director in the International Corporate Tax Group of KPMG in London. He joined KPMG London office in 1980 after completing his education in Naples (Italy) and then Cambridge (UK). He has worked full time for many years on cross- border tax planning for multinationals and has extensive knowledge and practical experience of the tax systems of many countries in Europe and elsewhere. As well as working with UK multinationals to structure outbound investment from the UK, Mario has assisted many non-European multinationals to structure their European operations. These include, among others, US, Canadian, Australian and Hong Kong SAR groups. He has also assisted several non-European groups in M&A transactions in Europe.
Raffaele Russo (Editor) is a Tax Treaty Advisor at the OECD. At the time of writing and editing this book, he worked as a Senior Associate at IBFD International Tax Academy (Amsterdam) and as a Tax Lawyer with NCTM Studio Legale Associato (Milan). He has a law degree from the University Federico II of Naples (Italy) and an LL.M in International Taxation from the University of Leiden (the Netherlands). Raffaele is a junior fellow of the International Tax Centre of the University of Leiden and a member of the Editorial Board of European Taxation and of Revista de Dereito Tributario Internacional.


“Delivers a professional's slant on the topic and while the book is a text on international tax law, the focus, as the title implies, is on international tax planning. Importantly, this is not a book on iternational tax avoidance... International tax planning is, in a sense, merely a way of restating 'international tax law' and demonstrating the consequences of that law in terms of examples and illustrative transactions. The emphasis is on the practical implications of international tax law, not analysis of the policy issues it raises... An easy-to-digest broad overview of the subject, highlighting the general rules and avoiding the distractions of technical specifics.”
Fundamentals of International Tax Planning - Book Review (2009) 38 AT Rev 125*
* This review was first published by Thomson Reuters in the Australian Tax Review and should be cited as Fundamentals of International Tax Planning - Book Review by Rick Krever, (2009) 38 AT Rev 125.

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