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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Much of it is now incorporated in statute. Intangible property is usually transferred by way of a licensing agreement, and payments for the intangible are made in the form of royalties. Among them, the Convention of 23 May on the Law of Treaties is particularly related to the interpretation of tax and other treaties.

You already recently rated this item. Please select Ok if you would like to proceed with this request anyway. The IRM guidelines do not confer any rights on taxpayers. This rule doesn’t prescribe priorities between various methods. The donee thereby becomes the owner of the property, but on the condition that the gift is revoked if the donor does not die. Such taxes are said to be shifted “backward” in the case that entrepreneurs are forced to absorb some of new or increased tax.

The taxable base for resident taxpayers is normally the taxpayer’s worldwide net worth, i.

IBFD international tax glossary in SearchWorks catalog

A taxpayer must spend more than the floor for a deduction, and only the amount above the ibfc is deductible. Rawlingdecided by the UK House of Lords ininvolved complicated tax avoidance scheme which were marketed in the UK in the s. The main international sources of tax law are bilateral or multilateral treaties, and one important source for the interpretation of treaties is the OECD model tax treaty and the accompanying inteernational.

The statement will show the business’s revenues and expenses. The term includes the process by which corporation internationql credits e. The theory is that this means foreign and domestic earnings of an entity will as far as possible be similarly taxed, although usually the credit allowed is limited to the amount of domestic tax, with no carry over if tax is higher abroad.


Usually, a certain minimum amount of nominal capital is required to establish a legal entity. Niternational mechanism is essentially one of adjusting payments, profits, gains, taxable income brackets, tax allowances, etc.

Unlike forward contracts, futures are tradable, reflecting the standardization of contract size, specification and delivery date. VAT normally utilizes a system of tax credits to place the ultimate and real burden of the tax on the final consumer and to relieve the intermediaries of any final tax cost.

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. However, the definitions vary according to country and situation. Don’t have an account?

View all subjects More like this Similar Items. 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. A limited partner only makes a financial contribution to the partnership and shares in the profits; he is liable for partnership obligations only to the extent of his investment.

She was formerly a tax litigator for the Federal Department of Justice in Canada, eventually starting her own tax law firm, Rogers-Glabush Law Office in Gift tax, death duties and property tax are also considered direct taxes. In US, the taxable income of a multistate corporation may be apportioned to a specific state only if the corporation has a sufficient nexus in the state.

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. It is a contribution to capital and not taxed as profits.


Centre for Tax Policy and Administration

This treaty creates a single economic and monetary union EMU. A formula is used to apportion the net income of the whole group to the various parts of the group. The name field is required. An independent contractor is hired to do work according to his own methods and is not subject to the control of an employer except as to the result of his work.

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IBFD International Tax Glossary – International Bureau of Fiscal Documentation – Google Books

It is mandatory in some countries and optional in others. Under the single entity approach, a head office and a permanent establishment gloesary treated as one taxpayer for tax purposes, even though they may be considered separate entities for purposes of accounting or commercial law. Non-residents are usually taxed on income derived from internationql within the taxing jurisdiction whereas residents may be taxed on worldwide income. 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 European Union.

The rate of interest is usually fixed. The tax is generally paid by the buyer but the seller is responsible for collecting and remitting the tax to the tax authorities.

Fringe benefits may be given in the form of a money allowance, e. Cookies are set by this site. The manufactured goods are resold to the parent for distribution to ultimate consumers. The process may or ibternational not include an audit of the taxpayer’s own books.