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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Although most countries tax the benefit of employer-provided automobiles and accommodation, the tax treatment of other fringe benefits varies considerably. The spread is taxed as ordinary income. In effect this method requires a comparison of the operating income that results from the consideration actually charged in a controlled transfer with the operating income of similar taxpayers that are uncontrolled.
This is called the super royalty provision.
IBFD International Tax Glossary – International Bureau of Fiscal Documentation – Google Books
This convention contains generally accepted rules applying to tax treaties, the conclusion of treaties, their observance, application and interpretation, etc.
Although VAT ultimately bears on individual consumption of goods or services, liability for VAT is on the supplier of goods or services. 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.
Generally, the income or expense is passed to the underlying owner. The portfolio interest exemption does not apply to bank loans made in the ordinary course of business. An equity or ownership interest in a corporation.
The E-mail message field is required. International double taxation arises when comparable taxes are imposed in two or more states ibffd the same taxpayer ihternational respect of the same taxable income or capital, e. However it is now commonly used as another way of referring to a company.
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IBFD international tax glossary
Fringe benefits may be given in the form of a money allowance, e. Controlled and uncontrolled transactions are comparable if none of the differences internatioal the transactions could materially affect the factor being examined in the methodology e. Thus, the basic return would generally not account for the return that would be generated by any unique and valuable assets possessed by the participants.
To this end the EU has issued directives in the area of indirect and direct taxation. Payments for know-how may be taxed as royalties in many cases.
Withholding taxes are found in practically all tax systems and are widely used in respect of dividends, interest, royalties and similar tax payments. Your request to send this item has been completed. According to OECD report, tax havens have the following key characteristics; No or only nominal taxes; Lack of effective exchange of information; Lack of transparency in the operation of the legislative, legal or administrative provisions.
The ownership interest possessed by shareholders in a corporation – stock as opposed to bonds. Examples are gllossary French and German systems.
In US, the taxable income of a multistate corporation may be apportioned to a specific state only if the corporation has a sufficient nexus in the state. Similar Items Related Subjects: However, the definitions vary according to country and situation. You may send this item to up to five recipients. A prison sentence may be imposed for serious tax fraud. There are legal reserves which may be required by company law and may be necessary before dividends are distributed. This term is used gloossary international shipping where a ship’s country of registration is selected on the basis of country’s legal requirement and tax regime.
Residence in a state is tlossary criteria for invoking a tax treaty of that state, and residence ibf treaty purposes involves considering the domestic law of residence for tax purposes, and then the requirements in Article 4 of the OECD Model, especially in the case of tiebreaker tests in cases of dual residence.
It has an especially significant role in international tax matters. It is not a separate legal entity. Generally a multi-step procedure will be provided to resolve the problem of dual residence, usually the place of a permanent home available being the first criterion. 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.
Cookies are set by this site. The tax embodied interntaional the price paid for the assets may be credited to the trader over a period of years corresponding to the life of the assets.
A captive insurance company interntional usually established in a low-tax country. The most extreme version of an OID is a zero-coupon bond, which internatoonal originally sold far below par value and pays no interest until it matures. Broadly speaking, it refers internationql the highest level of control of the business of a company.
Please create a new list with a new name; move some items to a new or existing list; or delete some items. 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.
In broader terms, in includes domestic legislation covering foreign income of residents worldwide income and domestic income of non-residents. A formula is used to apportion the net income of the whole group to the various parts of the group. Bad debts may usually be treated as losses and written off against a reserve for such debts.
Julie Rogers-Glabush Find more information about: Also this term is used to describe a system ultimately based on English legal systems, as opposed to civil law systems. inteernational
Formats and Editions of IBFD international tax glossary. 
In the case of indirect taxation tax is normally intended to fall upon consumption and be borne by consumers, so that entrepreneur who pays the tax on his supplies of goods and services in general passes on the tax, or “shifts” it “forward” to the consumer by adjusting his prices appropriately.
Paid-in capital plus retained earnings in a corporation. Accurate descriptions of both traditional and more obscure terms. Intangible property is usually transferred by way of a licensing agreement, and payments for the intangible are made in the form of royalties.
There is usually a deduction for the individual himself, spouse, children and other dependents. You may have already requested this item.