Tag Archives | International Taxation

Role of International Tax Planner

International tax planning revolves around the different tax systems in the world. The scope of taxation and tax rules differ widely. These differences create both opportunities and threats for international tax planning, and planners. For example: i. They often have differing tax rates on different sources of income (“taxable object”) and different tax treatment for […]

Participation Exemption for Taxation in Various Countries

Many jurisdictions define the term “participation exemption” widely to include any method used to avoid economic double taxation on inter-corporate dividends from shareholdings or participations. Therefore, it includes both the relief on dividend income under the special rules of “participation exemption” (also called “affiliation privilege”), and “dividend- received deduction.” Under the domestic participation exemption rules, […]

Imputation System of Taxation in Various Countries

In this article we will discuss about imputation system of taxation in various countries. The imputation system taxes a company and then grants a partial or full dividend credit to the shareholders against the corporate tax paid by the company. The shareholders claim the imputed credits and either offset them against their own tax liability […]

Tax System of Company Shareholders | International Taxation

Company Shareholder Taxation:: Under the classical or separate system of taxation, the company’s profits are taxed without any distinction between distributed and undistributed profits. The after-tax profits are taxed again in the hands of the shareholders (corporate or individual) when paid as dividends. As a result, the same profits are taxed twice: first at the […]

International Tax Structures

In this article we will discuss about International Tax Structures:- 1. Introduction to International Tax Structures 2. Examples of Tax-beneficial Structures 3. Forms of Business Entity 4. Financing of Overseas Entities. Introduction to International Tax Structures: Global tax management (e.g., planning) provides an opportunity to develop cross-border tax strategies to optimise global tax liabilities while […]

Tax Planning for Cross-Border Transactions

In this article we will discuss about:- 1. Conversion of a Foreign Branch to a Foreign Subsidiary 2. Repatriation of Profits 3. Liquidation of Companies 4. Cross-border Leasing 5. Foreign Direct Investment. Contents: Conversion of a Foreign Branch to a Foreign Subsidiary Repatriation of Profits Liquidation of Companies Cross-border Leasing Foreign Direct Investment 1. Conversion […]

Anti-Treaty Shopping | International Taxation

In this article we will discuss about:- 1. Introduction to Anti-Treaty Shopping 2. Impact 3. OECD Model Treaty and Commentaries 4. Beneficial Ownership Requirement 5. Various Countries 6. Comments. Contents: Introduction to Anti-Treaty Shopping Impact of Treaty Shopping Treaty Shopping under the OECD Model Treaty and Commentaries Beneficial Ownership Requirement Anti-Treaty Shopping in Various Countries […]

Determination of Arm’s Length Price | International Taxation

The following points highlight the top two methods for the determination of arm’s length price. The methods are: 1. Traditional Transaction Methods 2. Transactional Profit Methods. 1. Traditional Transaction Methods: (a) Comparable Uncontrolled Price Method (“CUP”): The price is based on the sale or purchase from an uncontrolled party, or from an uncontrolled transaction of […]

Transfer Pricing: Meaning, Transactions and Guidelines

In this article we will discuss about:- 1. Meaning of Transfer Pricing 2. Transactions Involving Transfer Pricing Issues 3. OECD 4. Guidelines 5. Domestic Tax Law 6. Tax Treaties 7. Various Countries. Contents: Meaning of Transfer Pricing Transactions Involving Transfer Pricing Issues OECD and Transfer Pricing Guidelines on Transfer Pricing Transfer Pricing under Domestic Tax […]

Top 6 Anti-Avoidance Measures for Taxation

The following points highlight the top six anti-avoidance measures for taxation. The measures are: 1. Exchange of Information 2. Transfer of Tax Residence and Exit Taxes 3. Exchange Controls 4. Branch Profits Tax 5. Use of Tax Havens 6. Anti-EC Directive Shopping Legislation. 1. Exchange of Information: The controls over international tax avoidance and evasion […]

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