Tag Archives | International Taxation

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 […]

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 […]

Taxpayers’ Rights and Obligations

In this article we will discuss about:- 1. Introduction to Taxpayers’ Rights and Obligations 2. Fundamental Rights 3. International Conventions on Human Rights 4. OECD Report 5. Charter 6. Selected Rights 7. Comments. Contents: Introduction to Taxpayers’ Rights and Obligations Fundamental Rights of Taxpayers Taxpayers’ Rights under International Conventions on Human Rights OECD Report on […]

Top 5 Techniques of Tax Planning

The following points highlight the top five techniques of tax planning. The techniques are: 1. Hybrid Entities: Check-the-Box Rules (United States) 2. Hybrid Financial Instruments 3. Derivative Financial Instruments (DFI) 4. Transfer Pricing and Tax Planning 5. Use of Offshore Trusts. Tax Planning: Technique # 1. Hybrid Entities: Check-the-Box Rules (United States): General: Prior to […]

Difference between Tax Evasion and Tax Avoidance

The upcoming discussion will update you about the difference between tax evasion and tax avoidance. Difference # Tax Evasion: Tax evasion implies an intention to avoid payment of tax where there is actual knowledge of liability. It usually involves deliberate concealment of the facts from the revenue authorities, and is illegal. Evasion does not generally […]

Judicial Anti-Avoidance Doctrines

In this article we will discuss about:- 1. Introduction to Anti-Avoidance Doctrines 2. Common Law for Anti-Avoidance Doctrines 3. Civil Law 4. Various Countries. Introduction to Anti-Avoidance Doctrines: International tax avoidance is also affected by the interpretations of judicial bodies in various countries. The practice varies considerably. The Courts in many countries take a literal […]

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