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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If a certain position has been taken, another person has relied on that, and you are aware of that reliance, there is often an estoppel against you arguing the contrary to your original position in a court proceeding. Information may only be used for tax purposes in the receiving country and it must be kept confidential, i.
CFC legislation is usually designed to combat the sheltering of profits in companies resident in low- or no-tax jurisdictions. Normally the ruling can be relied upon only by the taxpayer to whom it is issued, not by other taxpayers, and is binding upon the tax authority provided all relevant facts have been disclosed.
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.
Reciprocity is a basis for relieving a taxpayer under domestic law, e. This can be either an incorporated venture or an unincorporated venture.
The E-mail Address glssary field is required. This edition contains hundreds of new and revised terms, a list of tax courts and their location, and additional languages in the multilingual list of tax terms.
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Base companies carry interjational certain activities on behalf of related companies in high-tax countries e. Usually a resident taxpayer is taxed on a wider range of income or other taxable items than a non-resident. It typically includes expenses of the headquarters office and accounting expenses. This is equivalent to the tax on dividends which would be due if the branch had been a subsidiary see: Legal title to the trust property is vested in the trustee, while equitable title belongs to the beneficiaries.
For example, the spread of an option is the difference between the fair market value of stock at the exercise date and the option price. Examples are the French gloasary German systems. Instruments include contracts, notes, and leases e. The taxable base for resident taxpayers is normally the taxpayer’s worldwide net worth, i. IBFD vlossary tax glossary Author: Intangible property is usually transferred by way of a licensing agreement, and payments for the intangible are made in internstional form of royalties.
Over the term of the agreement, the parties exchange fixed or floating rate interest payments in their swapped currencies. 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.
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. For example, all depreciable assets of a similar kind are effectively treated as a single asset for depreciation purposes. Secondary transactions may take the form of constructive dividends, constructive equity contributions, or constructive loans.
Although most countries tax the benefit internqtional employer-provided automobiles and accommodation, the tax treatment of other fringe benefits varies considerably. The E-mail message field is required. This treaty creates a glossarry economic and monetary union EMU. A limited partner only makes a financial contribution to the partnership and shares in the profits; he is liable for partnership obligations only to the extent of his investment.
Ordinarily this basic return would be determined by reference to the market returns achieved for similar types of transactions by independent enterprises. Search WorldCat Find items in libraries near you. Find a copy in the library Finding libraries that hold this item Reviews User-contributed reviews Add a review and share your thoughts with other readers.
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. An independent contractor is hired to do work according to his own methods and is not subject to the control of an employer except as to the result of his work.
Another model is UN model. Many countries levy income tax on this basis. The report generally consists of a balance sheet, income statement and may include other information as well. The cost of general services such as management, administrative and similar services may be often allocated among the various members of the group without any profit mark-up, whereas services performed in the ordinary course of business are subject to arm’s length conditions.
Please enter the message. Often occurs in the case of a partnership for example. Advanced Search Find a Library. 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. Usually, stamp duties are “levied” by way of a stamp being fixed to the document in question.
IBFD International Tax Glossary, 7th Edition | Book – IBFD
The case established that a series of transactions with the purpose of tax avoidance, which ultimately cancelled each other out, could be ignored for tax purposes. Location of immovable property in a country means, in most countries, that the country taxes the income derived therefrom and possibly the value and capital gains realized on alienation, even if the owner is not a resident of that country.
Low-income person or family would receive a direct subsidy, called a negative income tax. Also known as hour trading since the transactions are carried out continuously during a day in financial markets worldwide. The term “place of management” as such is not defined in the OECD model tax treaty, but may be defined in national tax law.
Undue hardship is a condition precedent to the granting of an extension of time to make a tax payment.