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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Paid-in capital plus retained earnings in a corporation.
The rights of ordinary shareholders to receive dividends are generally subordinate to the rights of bond holders and preference shareholders. Artificial schemes which create circumstances under which no tax or minimal tax is levied may be disregarded if they do not serve a “business purpose”.
The OECD model treaty does not allow glosdary of it. Legal title to the trust property is vested in the trustee, while equitable title belongs integnational the beneficiaries.
It made ineffective tax avoidance schemes which have no commercial purpose other than the avoidance of tax. Find a copy in the library Finding libraries that hold this item Repatriation also takes place when expatriate employees working in a foreign country want to send income ta their home country. The holder of common stock usually has a vote in deciding company affairs. The formula equally weights the payroll factor, property factor, and sales factor.
It is a contribution to capital and not taxed as profits. By virtue of the Union Treaty, the former European Economic Community has been extended with additional goals and powers in order to become a single market in a Tqx Union.
The most extreme version of an OID is a zero-coupon bond, which is originally sold far below par value and pays no interest until it matures.
These are financial instruments whose values are linked to or depend on the value of a primary underlying asset, e. Under the single entity approach, a head office and a permanent establishment are treated as one taxpayer glossarry tax purposes, even though they may be considered separate entities for purposes of accounting or commercial law. There are legal reserves which may be required by company law and may be ubfd before dividends are distributed.
Portfolio investors may receive different internayional relief or other treatment in respect of their dividends under tax treaties from those accorded to other direct investors. The income is then taxed at a single progressive rate. In the ibfx stage, each participant is allocated sufficient profit to provide it with a basic return appropriate for the type of transactions in which it is engaged.
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. All partners in an ordinary partnership are general partners. The statement will show the business’s assets in one column and its liabilities and owner’s equity in another column. Tax law does not allow a deduction inyernational such a reserve.
If the reported operating income of the tested party is not within a certain range, an adjustment will be made. Over the term of the tlossary, the parties exchange fixed or floating rate interest payments in their swapped currencies. The primary types of derivatives include forward contracts, futures, options and swaps.
Generally, only certain types of income fall within the scope of CFC legislation, i. Multilingual list of tax terms. A general partnership is characterized by the unlimited liability of lgossary general partners for partnership debts. This is called the super royalty provision. We’ve updated our Terms and Conditions. Intangible property is usually transferred by way of a licensing agreement, and payments for the intangible are made in the form of royalties.
Another model is UN model. Would you also like to submit a review for this item? In the context of a bond or other debt instrument, it is the amount paid in excess of the face amount. There are also Vienna Conventions on Diplomatic and Consular Relations, which address taxation and other issues in that context.
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To learn more, view our cookies statement page. Instruments include contracts, notes, and leases e. Eurobonds may take the form of loans, debentures or convertible debentures, and maybe designated in any currency. Controlled and uncontrolled glossarg are comparable if none of the differences between the transactions could materially affect the factor being examined in the methodology e.