Abstract:
The purpose of this paper is an examination of the relationship between taxation and the working of
international banking arrangements. The main task is directed to the ways taxation determinations by
national authorities affect the ways international banks go about their business. International
coordination through the Organisation for Economic Co-operation and Development (OECD) is a
major focus of the analysis. There is no general exposition of principles bearing upon international
taxation. Rather, attention is directed to the determination of tax obligations in anyone jurisdiction.
Thus, there is a close scrutiny of the mechanics of taxation in the international setting bringing out the
uncertainties and the imponderables in any application. Much attention is given to structural
arrangement in international banking as well as capital arrangements in anyone jurisdiction and how
this applies to and affects the banking group as a whole. The result is to bring out the complexity of the
agenda for tax applications on a common basis across internationally operating groups. Most
jurisdictions recognise that they cannot await common agreements because new instruments and
arrangements emerge at very frequent intervals and their tax implications have to be addressed. There
has to be relief from uncertainty if markets are to develop effectively. Thus, there is in an importance
sense of partnership between tax authorities and market participants in many countries. International
deliberations have taken too long.
