IBFD International Tax Glossary. Front Cover · International Bureau of Fiscal Documentation. IBFD, – Taxation – pages. Get this from a library! IBFD international tax glossary. [Julie Rogers-Glabush;]. international tax glossary by Julie Rogers-Glabush · IBFD international tax glossary. by Julie Rogers-Glabush; International Bureau of Fiscal Documentation ;.
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Search WorldCat Find items in libraries near you. Base companies carry on certain activities on behalf of internatonal companies in high-tax countries e. What is arrived at after adding the cost plus mark up to the above costs may be regarded as an arm’s length price of the original controlled transaction.
For example, the rules may provide that certain consequences will follow if the sole, main or principal purpose of certain transaction is the reduction of tax.
Controlled and uncontrolled transactions are comparable if none of the differences between the transactions could materially affect infd factor being examined in the methodology e.
The case established that a series of transactions with the purpose of tax avoidance, which ultimately cancelled each other out, could be ingernational for tax purposes. Also known as an “S corporation”, this form permits income at the corporate level to be taxed only once at the shareholder level. If income received from abroad is subject to tax in glossay recipient’s country, any foreign tax on that income may be credited against the domestic tax on that income.
A number of countries have adopted special regimes to deal with cross-border reinsurance.
IBFD international tax glossary
A number of countries have special regime for the taxation of offshore banks. Exemptions may be given for social, economic or other reasons.
For example, under tax treaties, reduced withholding tax rates often apply to dividends, interest and royalties.
Goodwill can be transferred for a consideration to another entrepreneur upon the sale of the business as a going concern. It refers to the period of time a taxpayer spends in each country. Advanced Search Find a Library. Similar Items Related Subjects: In certain countries a tax clearance certificate must be produced before a person can leave the country. Usually a combination of property, payroll, turnover, capital invested, manufacturing costs, etc.
Long-term capital glosssry may be taxed at reduced rates. This is called the super royalty provision. VAT normally utilizes a system of tax credits to place the ultimate and real burden of the tax on the final consumer and to relieve the intermediaries of any final tax cost. Rawlingdecided by the UK House of Lords ininvolved complicated tax avoidance scheme which were marketed in the UK in the s. Artificial schemes which create circumstances under which no tax or minimal tax is levied may fax disregarded if they do not serve a “business purpose”.
In the context of a bond or other debt instrument, it is the amount paid in excess of the face amount. The tax is generally paid by the buyer but the seller is responsible for collecting and remitting the tax to the tax authorities. A trade often implies a skilled handicraft, which is pursued on a continuing basis, such as carpentry.
Generally speaking, two approaches are taken to foreign tax relief, i. Please enter recipient e-mail address es. A general partner is involved in the management and day-to-day operation of the partnership and is jointly and severally liable for all obligations of the partnership.
IBFD international tax glossary in SearchWorks catalog
Cancel Forgot your password? Multilingual list of tax terms. A unique list of tax-related organizations in 40 countries, with brief descriptions and Internet addresses. The decisive criterion is whether the activity of the fixed place of business in intwrnational forms an essential and significant part of the glsosary of the enterprise as a whole.
Your request to send this item has been completed. An advance pricing arrangement may be unilateral involving one tax administration and a taxpayer or multilateral involving the agreement of two or more tax administrations.
The theory is that this means foreign and domestic earnings of an entity will hlossary far as possible be similarly taxed, although usually the credit allowed is limited to the amount of domestic tax, with no carry over if tax is higher abroad. DE MINIMIS — Phrase used in connection with circumstances in which the full rigour of the tax law is not enforced because, in particular, of the small amount or minor breach which may be involved, particularly in the context of under-assessed or underpaid tax which are not pursued on “de minimis” grounds.
In the context of transfer pricing, one method to estimate an arm’s length price for transactions between affiliated companies is to increase the supplier’s cost by an appropriate profit mark-up Cost-plus method.
The purposes of the IMF are, inter alia, to promote international monetary cooperation, facilitate the expansion and balance growth of international trade and promote stability in foreign exchange. The third party then assumes responsibility for the administration and collection of the debt on the due date for its own account. It made ineffective tax avoidance schemes which have no commercial internationa other than the avoidance of tax. An essential feature of such regimes is that they attribute gpossary proportion of the income sheltered in such companies to the shareholder resident in the country concerned.
Julie Rogers-Glabush Glossagy more information about: Substance over form doctrine.
IBFD International Tax Glossary – International Bureau of Fiscal Documentation – Google Books
Upon exercising an option for separate taxation, a husband and wife are treated as separate individuals for the purpose of computing income tax. The term is normally applied to a situation where a person not resident of either the treaty countries establishes an entity in one of the treaty countries in order to obtain treaty benefits. The gglossary usually refers to net working capital, that is, current asset minus current liabilities. This treaty creates a single economic and monetary union EMU.
In glosxary first stage, each participant is allocated sufficient profit to provide it with a basic return appropriate for the type of transactions in which it is engaged. Usually, a certain minimum amount of nominal capital is required glosszry establish a legal entity.
Such a distribution would constitute a taxable dividend to the shareholder to the extent of current and accumulated earnings and profit under US tax law. Common stock is usually last in priority when profits or assets are distributed. Please select Ok if you would like to proceed with this request anyway. Reviews User-contributed reviews Add a review and share your thoughts with other readers.