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 ;.
|Published (Last):||21 January 2013|
|PDF File Size:||15.61 Mb|
|ePub File Size:||13.65 Mb|
|Price:||Free* [*Free Regsitration Required]|
A unique list of tax-related organizations in 40 countries, with brief descriptions and Internet addresses. S government that prints the regulations of the various governmental agencies. The IRM guidelines do not confer any rights on taxpayers.
The decisive criterion is whether the activity of the fixed place of business in itself forms an essential and significant part of the activity of the enterprise as a whole. Please select Ok if you would like to proceed with this request anyway. If a corporate debt is disproportionately high in comparison with its equity, the debt may be recharacterised as equity, resulting in a disallowance of the interest deduction and taxation of the funds as dividends.
It is a contribution to capital and not taxed as profits. The statement will show the business’s revenues and expenses. Among them, the Convention of 23 May on the Law of Treaties is particularly related to the interpretation of tax and other treaties. Most corporations receive no deduction for it.
A variety of criteria, including share gloxsary ratio, may be employed to determine whether one company is a subsidiary of another company for tax purposes. Payments for know-how may be taxed as royalties in many cases. If a certain position has been taken, another person has relied on that, and inteenational are aware of that reliance, there is often an estoppel against you arguing the contrary to your original position in a court proceeding. Or portfolio of securities held by an investment company on behalf of investors.
There are also Vienna Conventions on Diplomatic and Consular Relations, which address taxation and other issues in that context. Secondary transactions may take the form glossarg constructive dividends, constructive equity contributions, or constructive loans.
Gift tax, death duties and property tax are also considered direct taxes. Don’t have an account?
IBFD international tax glossary
In EU context, it means one of the legal instruments issued by the competent institutions of the European Union. In many countries the gratuitous transfer of property is subject to a gift tax. Undue hardship is a condition precedent to the granting of an extension of time to make a tax payment. Finding libraries that hold this item Other countries do not consider a partnership to be a separate legal entity and the partnership is treated as tax transparent, with each individual partner being taxed on his share of the profits according to his interest in the partnership.
For example, the spread of an option is the difference between the fair market glosssary of stock at the exercise date and the option price.
Cancel Forgot your password? Cross-referenced listing of terms indicating similar, related and contrasting terms.
IBFD International Tax Glossary, 7th Edition | Book – IBFD
Please choose whether or not you want ibbfd users to be able to see on your profile that this library is a favorite of yours. A trade often implies a skilled handicraft, which is pursued on a continuing basis, such as carpentry. Synonym for progressive rate. Please verify that you are not a robot. 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.
They are not considered to necessarily reflect official position of the OECD in interpreting international tax terms, for example, in the tax treaty context. As a general rule, the provisions of a tax treaty implemented domestically prevail over other domestic legislation.
In a mortgage that states an insufficient interest rate, tax law will impute a higher rate and a intenational principal, which will increase taxes on the receipt of payment. The term usually refers to net working capital, that is, current asset minus current liabilities. Dependent agency constitutes a permanent establishment for the other company and the income achieved through the agency is taxed on the income earned from the country where the agency is located whereas independent agency does not.
A tax holiday offers a period of exemption from income tax for new industries in order to develop or diversify domestic industries. Many tax treaties include a clause that the right to tax income arising from outside the state is internationa, to the sending state. However, the definitions vary according to country and situation.
A finance company is, in many cases, established in a low or no tax jurisdiction. It is not a separate legal entity. The ownership interest possessed by shareholders in a corporation – stock as opposed to bonds.
Base companies carry on certain activities on behalf of related companies in high-tax countries e. Whether premiums paid to captive insurance companies are recognized as business expenses depends on the country in question. WorldCat is the world’s largest library catalog, helping you find library materials online.
Both treaty countries appoint a representative frequently the Ministry of Finance or its authorized representative as the CA to assist aggrieved taxpayers by acting as the official liaison with the foreign CA.
Subjects Taxation — Encyclopedias. The case established that a series of gossary with the purpose of tax avoidance, which ultimately cancelled each other out, could be ignored for tax inteernational. Abbreviations and bibliographical references to aid further research. This procedure, described and authorized by Article 25 of the OECD Model Tax Convention, can be used to eliminate double taxation that could arise from a transfer pricing adjustment.
Ordinarily this basic return would be determined by reference to the market returns achieved for similar types of transactions by independent enterprises.