An essential feature of such regimes is that they attribute a proportion of the income sheltered in such companies to the shareholder resident in the country concerned. As a general rule, the provisions of a tax treaty implemented domestically prevail over other domestic legislation. Examples include VAT, sales tax, excise duties, stamp duty, services tax, registration duty and transaction tax { bidder: 'ix', params: { siteId: '195453', size: [320, 100] }},
FUNCTIONAL ANALYSIS -- An analysis of the functions performed (taking into account assets used and risks assumed) by associated enterprises in controlled transactions and by independent enterprises in comparable uncontrolled transactions. FRAUD -- Tax fraud is a form of deliberate evasion of tax which is generally punishable under criminal law. TRADE -- A business, profession, or occupation. PRICE INCREASE RESERVE -- Reserve to take account of expected increase in prices of goods, raw materials, etc. {code: 'ad_btmslot_a', pubstack: { adUnitName: 'cdo_btmslot', adUnitPath: '/2863368/btmslot' }, mediaTypes: { banner: { sizes: [[300, 250], [320, 50], [300, 50]] } }, AMORTIZATION METHOD -- Method of computing a credit under a VAT regime where investment goods are purchased which have a useful life in the business for a period exceeding one year. 408 Rebroadcast), ADP, the biggest U.S. payroll service, won’t implement Trump’s ‘tax holiday’ for some clients, Houellebecq’s Incendiary Novel Imagines France With a Muslim President, 2014 Was a Delectably Good Year for Sleaze. RESIDENT -- A person who is liable for tax in a country or state because of domicile, residence, place of management, or other similar criterion. TAX SPARING CREDIT -- Term used to denote a special form of double taxation relief in tax treaties with developing countries. name: "_pubcid", The test determines that in such cases the company would, for treaty purposes, be resident in the state in which its place of effective management is situated. {code: 'ad_rightslot', pubstack: { adUnitName: 'cdo_rightslot', adUnitPath: '/2863368/rightslot' }, mediaTypes: { banner: { sizes: [[300, 250]] } }, Does Anyone Really Know What Socialism Is? RETURN -- Declaration of income, sales and other details made by or on behalf of the taxpayer. type: "cookie", HABITUAL ABODE -- In the context of the tie-breaker rule of the OECD model tax treaty, habitual abode is one of the criteria used to resolve the problem of dual residence. { bidder: 'triplelift', params: { inventoryCode: 'Cambridge_MidArticle' }}, imputation credits or foreign tax credits) received to net income received before calculating their tax liabilities. { bidder: 'pubmatic', params: { publisherId: '158679', adSlot: 'cdo_mpuslot3' }}]}];
UNDERLYING TAX CREDIT -- See: Credit, underlying tax name: "identityLink",
The cash benefits are not taxed and the veterans are often granted, Understanding how taxation affects human capital accumulation is therefore important for the evaluation of. The OECD model treaty does not allow application of it. PRIVILEGED TAX REGIME -- Euphemism for the tax regime of a tax haven. PLACE OF EFFECTIVE MANAGEMENT -- Place of effective management is the test suggested in the tie-breaker rule of the OECD model tax treaty to determine the residence of a company where under the domestic laws of both contracting states the company is resident in both of them. CONTRACT MANUFACTURER -- A manufacturer, in most cases, located in a low-cost jurisdiction, which has a license to use an intangible property developed by its parent company. What constitutes a legal entity for tax purposes may or may not coincide with what constitutes a legal entity for general law purposes. CAPTIVE INSURANCE COMPANY -- Wholly owned subsidiary of a multinational group of companies which exclusively insures or reinsures the risks of companies that belong to the group.
{ bidder: 'appnexus', params: { placementId: '11654208' }}, bids: [{ bidder: 'rubicon', params: { accountId: '17282', siteId: '162036', zoneId: '776156', position: 'atf' }}, JUNK BOND -- Bonds and debentures issued by companies that have a low credit evaluation (i.e.
{ bidder: 'ix', params: { siteId: '195453', size: [300, 50] }}, { bidder: 'sovrn', params: { tagid: '448839' }}, The term includes the process by which corporation add credits (e.g. Common stock is usually last in priority when profits or assets are distributed.
The process may or may not include an audit of the taxpayer's own books. { bidder: 'pubmatic', params: { publisherId: '158679', adSlot: 'cdo_leftslot' }}]}, INHERITANCE -- Real property or personal property that is received by heirs. { bidder: 'triplelift', params: { inventoryCode: 'Cambridge_SR' }}, TAX PLANNING -- Arrangement of a person's business and /or private affairs in order to minimize tax liability. { bidder: 'pubmatic', params: { publisherId: '158679', adSlot: 'cdo_btmslot' }}]}, FINANCIAL STRUCTURE -- The makeup of the right-hand side of a company's balance sheet, which includes all the ways it assets are financed.
FIXED BASE -- This term was used in the OECD and UN model tax treaties in the context of independent personal services, but the former Article 14 has been removed from the OECD Model and these issues are now generally dealt with under Article 7, dealing with business profits attributed to permanent establishments. Withholding taxes are found in practically all tax systems and are widely used in respect of dividends, interest, royalties and similar tax payments. { bidder: 'ix', params: { siteId: '195456', size: [300, 250] }}, COMMODITY TAX -- Tax based on a selective number of commodities. SUBSTANCE OVER FORM DOCTRINE -- Doctrine which allows the tax authorities to ignore the legal form of an arrangement and to look to its actual substance in order to prevent artificial structures form being used for tax avoidance purposes. var pbMobileHrSlots = [ var pbHdSlots = [ SALE AND LEASEBACK -- In a sale and leaseback transaction, the owner of property will sell it to a buyer who then leases it back to the original owner. CONTROLLED TRANSACTION -- Transactions between two enterprises that are associated enterprises with respect to each other.
FRIVOLOUS POSITION -- A tax position that is knowingly advanced in bad faith and is patently improper. { bidder: 'pubmatic', params: { publisherId: '158679', adSlot: 'cdo_mpuslot2' }}]}, Please tell us where you read or heard it (including the quote, if possible). LIMITED PARTNERSHIP -- Business entity made up of two types of partners: general partners and limited partners, the extent of whose liability depends on their role and contribution to partners.
bids: [{ bidder: 'rubicon', params: { accountId: '17282', siteId: '162036', zoneId: '776140', position: 'atf' }},
{ bidder: 'ix', params: { siteId: '195457', size: [300, 250] }}, -- An official published statement by the IRS of US about procedural and administration aspects of the tax laws.
'increment': 1, { bidder: 'onemobile', params: { dcn: '8a969411017171829a5c82bb4deb000b', pos: 'cdo_mpuslot_flex' }},
REGULATED INVESTMENT COMPANY (RIC) -- Company, also known as a mutual fund, formed under US law to make diversified investment with funds provided by investors who receive dividends and capital gains realized by RIC. CUSTOMS DUTIES -- Taxes on goods imported into a country.
{ bidder: 'criteo', params: { networkId: 7100, publisherSubId: 'cdo_mpuslot' }},
USEFUL LIFE -- Period during which it is estimated that a depreciable asset will provide useful service to the business in which it is used. PENALTIES -- Administrative penalties are imposed for tax offences, such as failure to make a timely return or payment, negligence, and making a false return or statement. DOUBLE TAXATION, DOMESTIC AND INTERNATIONAL -- Domestic double taxation arises when comparable taxes are imposed within a federal state by sovereign tax jurisdictions of equal rank. BASE COMPANY -- Company situated in a low-tax or non-tax country (i.e. BROTHER-SISTER CORPORATIONS -- Two or more companies which are owned and controlled by the same shareholders. This contract serves the same purpose as a foreign currency futures contract, except that it is not standardized and entered on the informal, interbank market rather than on a formalized commodities exchange. CONSORTIUM -- Association of business enterprises, whether individuals, partnerships or companies, operating together on a temporary basis for some specific venture. Also this term is used to describe a system ultimately based on English legal systems, as opposed to civil law systems. MEMORANDUM OF UNDERSTANDING (MOU) -- In the context of a tax treaty, a document exchanged between the treaty partners which sets out the understanding of the parties regarding the convention. { bidder: 'ix', params: { siteId: '195456', size: [300, 250] }}, TAX FORM -- It is usual to design special forms for taxpayers to declare their taxable income, sales, etc. EXCHANGE CONTROL -- Restriction of the amount of a particular foreign currency that can be bought or sold The income is taxed at the parent's highest rate of tax. 'buckets': [{ { bidder: 'ix', params: { siteId: '195451', size: [300, 50] }}, CIF VALUE -- The value of imported goods which includes cost, insurance and freight. DEBT/EQUITY RATIO -- Relationship of total debt of a company to its ordinary share capital.
{ bidder: 'appnexus', params: { placementId: '11654151' }}, Restricted stock is includable in the gross income of the employee in the first taxable year in which the rights become transferable or no longer subject to forfeiture.
AD VALOREM TAX -- A tax on goods or property expressed as a percentage of the sales price or assessed value A partnership can be a general partnership or a limited partnership depending on the extent of each party's liability. { bidder: 'appnexus', params: { placementId: '11653860' }},
dfpSlots['leftslot'] = googletag.defineSlot('/2863368/leftslot', [[120, 600], [160, 600]], 'ad_leftslot').defineSizeMapping(mapping_leftslot).setTargeting('sri', '0').setTargeting('vp', 'top').setTargeting('hp', 'left').setTargeting('ad_group', Adomik.randomAdGroup()).addService(googletag.pubads());
TAX RETURN -- See: Return addPrebidAdUnits(pbAdUnits); { bidder: 'onemobile', params: { dcn: '8a969411017171829a5c82bb4deb000b', pos: 'cdo_rightslot2_flex' }}, Learn a new word every day. { bidder: 'triplelift', params: { inventoryCode: 'Cambridge_SR' }}, For example, under tax treaties, reduced withholding tax rates often apply to dividends, interest and royalties. ), usually in proportion to the value of money involved. The inventor of a new article or process usually registers his invention with a government department which confers on him the sole right (known as a patent right) to use the invention for a limited period of time. var mapping_contentslot = googletag.sizeMapping().addSize([746, 0], [[300, 250], [336, 280], 'fluid']).addSize([0, 0], [[300, 250], [320, 100], [320, 50], [300, 50], 'fluid']).build(); "Government wanted to tax them for imperial purposes," said Gordon. {code: 'ad_contentslot_1', pubstack: { adUnitName: 'cdo_mpuslot', adUnitPath: '/2863368/mpuslot' }, mediaTypes: { banner: { sizes: [[300, 250], [336, 280]] } }, "authorizationTimeout": 10000
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