International Tax Planning

  • Derek F. Channon
  • Michael Jalland


The planning of the international tax position in the MNC has become a vital factor in investment decisions, capital structure, working capital management and overall corporate profitability. Tax planning is an extremely complex management task since the rules are constantly changing. It is not possible therefore in this chapter to cover the subject in detail since the topic is too large and the results would be obsolescent almost as they were written. Rather the intention is to examine briefly the main mechanisms used for tax reduction and to illustrate the effects of some of these. Detailed considerations for the individual corporation must be developed on a unique basis, to meet the specific strategic needs and objectives of the enterprise concerned.


Capital Gain Transfer Price Interest Payment Royalty Payment Permanent Establishment 
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  1. 1.
    H. Schollhammer, Locational Strategies of Multinational Corporations (1972).Google Scholar
  2. 2.
    Information Guide for U.S. Corporations Doing Business Abroad’ New York, Price Waterhouse and Co.), included in Stonehill and Stitzel, op. cit., pp. 169–77.Google Scholar
  3. 3.
    Summary Study of International Cases Involving S482 of the IRC’, US Treasury Department, 1973.Google Scholar
  4. 4.
    See D. F. Channon, ‘Hoffman la Roche’, MBS/IB/10, Manchester Business School, 1975.Google Scholar
  5. 5.
    M. Edwardes Ker, International Tax Strategy (In Depth Publishing Ltd. 1975), chapter 5, p. 3.Google Scholar
  6. 6.
    Ibid., chapter 7, p. 13.Google Scholar
  7. 7.
    Ibid., chapter 7, pp. 22–3.Google Scholar
  8. 8.
    John F. Chown, Taxation and Multinational Enterprise (Longmans, 1974), p. 86.Google Scholar
  9. 9.
    Edwardes Ker, op. cit., chapter 9, pp. 7–10.Google Scholar
  10. 10.
    J. C. S. Kimber, op. cit.Google Scholar
  11. 11.
    Chown, op. cit., pp. 139–40.Google Scholar
  12. 12.
    Ibid., pp. 144–6.Google Scholar
  13. 13.
    Edwardes Ker, op. cit., chapter 32, p. 8.Google Scholar
  14. 14.
    Ibid., chapter 32, p. 13.Google Scholar
  15. 15.
    Chown, op. cit., p. 123.Google Scholar
  16. 16.
    Ibid., pp. 128–9.Google Scholar

Copyright information

© Derek F. Channon with Michael Jalland, Manchester Business School 1978

Authors and Affiliations

  • Derek F. Channon
    • 1
  • Michael Jalland
    • 1
  1. 1.Manchester Business SchoolUK

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