The Architecture of International Taxation A Global Framework

International taxation has an extraordinary body of literature - multi-volume treatises, 3,000-page commentaries, journals that dissect every OECD paragraph with surgical precision. Yet the professionals who need to understand cross-border tax most urgently are often the least served by it. A CFO evaluating a cross-border acquisition does not need a encyclopedia. A private equity partner assessing tax exposure does not have three weeks to study the arm's length principle from first principles. This book fills that gap.
What's Inside
Built on the OECD Model Tax Convention, the UN Model, and the multilateral instruments that constitute the global tax framework, this book covers:
Treaty architecture - how 3,000+ bilateral tax treaties allocate taxing rights between residence and source states, and how the Multilateral Instrument rewired the network
Distributive rules decoded - dividends, interest, royalties, capital gains, employment income, and the ordering rules that determine which article governs each payment
Permanent establishments - fixed place, agency, and construction PEs, including post-BEPS commissionnaire rules and the 2025 OECD remote-work guidance
Transfer pricing - the arm's length principle, five OECD methods, DEMPE framework, Amount B, comparability analysis, and three-tier documentation
Anti-avoidance - CFC rules, thin capitalisation, interest limitation, the Principal Purpose Test, and Limitation on Benefits
BEPS and the MLI - all 15 Actions, four minimum standards, and the matching mechanism that makes the MLI operational
Pillar One and Pillar Two - Amount A reallocation, Amount B standardisation, the GloBE Rules, QDMTT, IIR, UTPR, ETR computation, and the Substance-Based Income Exclusion
Frontier chapters - AI and the international tax framework, digital services taxes, CBAM carbon border adjustments, crypto-asset reporting (CARF), and ESG tax transparencyEvery chapter includes worked numerical examples with sensitivity analysis, multi-entity corporate scenarios, decision flowcharts, and practitioner insights drawn from 14+ years of Big 4 advisory across three continents.
Jurisdiction-neutral by design. No chapters on Indian domestic law. No sections on the US Internal Revenue Code. Built on the international framework - useful in Dubai, Delhi, London, São Paulo, and Singapore.
Current through early 2026 - covers the November 2025 OECD Model Update, the Pillar Two Side-by-Side package, CBAM's definitive phase, CARF's first reporting period, and the UN Framework Convention negotiations.
Who This Book Is For
Group tax directors and CFOs who need the conceptual architecture, not a 3,000-page referenceM&A and private equity professionals assessing cross-border tax riskADIT, CIOT, and CPA exam candidates seeking a single supplementary textTransfer pricing practitioners building broader international tax fluencyLLM and MTax students who want worked examples alongside doctrine
About the Author
Ajit Kumar Jain is a transfer pricing and international tax practitioner with 14+ years of Big 4 experience across PwC and KPMG in India, the Middle East, and the United Kingdom. He holds dual Chartered Accountant qualifications (ICAEW and ICAI), the ADIT, and has published research in the IBFD International Transfer Pricing Journal. He serves as the exclusive UAE Transfer Pricing Diploma educator for Kaplan MENA.

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