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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Where a country grants tax incentives to encourage foreign investment and that company is a resident of another country with which a tax treaty has been concluded, the other country may give a credit against its own tax for the tax which the company would have paid if the tax had not been “spared i. Where expenditure is more closely connected with the business income-earning structure than its income earning capacity, it is capital expenditure.

Similarly, a withdrawal of goods or services for private use constitutes a taxable transaction for VAT purposes in most countries using such a system. Some features of WorldCat will not be available. 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.

Cancel Forgot your password? You already recently rated this item. A captive insurance company is usually established in a low-tax country. S government that prints the regulations of the various governmental agencies. Secondary transactions may take the form of constructive dividends, constructive equity contributions, or constructive loans. Please enter recipient e-mail address es. 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.

IBFD International Tax Glossary, 7th Edition | Book – IBFD

A variety of criteria, including share ownership ratio, may be employed to determine whether one company is a subsidiary of another company for tax purposes. Unlike forward contracts, futures are tradable, reflecting the standardization of contract size, specification and delivery date.


Portfolio investors may receive different tax relief or other treatment in respect of their dividends under tax treaties from those accorded to other direct investors. International double taxation arises when comparable taxes are imposed in two or more states on the same taxpayer in respect of the same taxable income or capital, e. Residents are not taxed on any foreign-source income. The lessee is regarded as the owner of the leased assets.

As a general rule, with some exceptions, the right to tax income from dependent personal services is allocated to the country where the employment activities are exercised.

IBFD international tax glossary

Remember me on this computer. It has an especially significant role in international tax matters. Business entities — Appendix III: The mechanism is essentially one of adjusting payments, profits, gains, taxable income brackets, tax allowances, etc.

Abusive transfer pricing occurs when income and expenses are improperly allocated for the purpose of reducing taxable income.

The process may or may not include an audit of the taxpayer’s own books. Location of gloseary property in a country means, in most countries, internztional 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.

The report generally consists of a balance sheet, income statement and may include other information as well. Options include corporations, partnerships, estates and trusts. Write a review Rate this item: 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.

Fringe benefits may be given in the form of a intefnational allowance, e. They take the form of additions to the tax and are assessed as part of the tax. Intednational portfolio interest exemption does not apply to bank loans made in the ordinary course of business.


Free access to IBFD Online Tax Glossary – IBFD

Reciprocity is a basis for relieving a taxpayer under domestic law, e. 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. Please enter your name. However it is now commonly used as another way of referring to a company. Also known as hour trading since the transactions are carried out continuously during a day in financial markets worldwide. Some countries treat a partnership as a separate taxpayer and may subject it to tax on its income and losses as a corporation.

It denotes a centre of activity of a fixed or permanent character from which such services can be carried out such as a physician’s consulting room. In the context of a bond or other debt instrument, it is the amount paid in excess of the face amount. Your list has reached the maximum number of items. In broader terms, in includes domestic legislation covering foreign income of residents worldwide income and domestic income of non-residents.

Abbreviations and bibliographical references to aid further research. The specific requirements or preferences of your reviewing publisher, classroom teacher, institution or organization should be applied. Generally, only certain types of income fall within the scope of CFC legislation, i.

Interest is credited on the deposit ylossary the Inland Revenue. The OECD model treaty does not allow application of it. A trader’s operating losses constitute broadly the excess of his operating expenditure over receipts from his operations.

Free book sample with table of contents and sample chapter. The rate of interest is usually fixed.

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