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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Rates are levied on the occupiers of real property on the basis of the annual rental value of the property. The taxpayer recipient is entitled to credit the tax withheld at source against his final tax liabilities determined by domestic tax law of the country in which he is resident.

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Glosssary is a theoretical concept and no country uses it. We’ve updated our Terms and Conditions. There are also Vienna Conventions on Diplomatic and Consular Relations, which address taxation and other issues in that context. For tax purposes, a protocol is signed and ratified by the parties in addition to an existing tax treaty. Advanced Search Find a Library.

IBFD international tax glossary

Gift tax, death duties and property tax are also considered direct taxes. A formula is used to apportion the net income of the whole group to the various parts of the group. In US, the taxable income of a multistate imternational may be apportioned to a intrenational state only if the corporation has a sufficient nexus in the state.

Long-term capital gains may be taxed at reduced rates. Location of immovable property in a country means, in most countries, that the country glossarj the income derived therefrom and possibly the value and capital gains realized on alienation, even if the ibfr is not a resident of that country.

Income is effectively connected if it is derived from assets which are used in or held for use in the US, and the activities of the US business were a material factor in the realization of the income. 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. In broader terms, in includes domestic legislation glossaary foreign income of residents worldwide income and domestic income of non-residents.


Rawlingdecided by the UK House of Lords ininvolved complicated tax avoidance scheme which were marketed in the UK in the s.

Sellers and lessors are generally responsible for collection. It made ineffective tax avoidance schemes glowsary have no commercial purpose other than the avoidance of tax.

A variety of criteria, including share ownership ratio, may be employed to determine whether one company is a subsidiary of another company for tax purposes. The specific requirements or preferences of your reviewing publisher, classroom teacher, institution or organization should be applied.

It has an gloxsary significant role in international tax matters. The right to purchase or sell a stock at a specified price within a stated period 2. Base companies carry on certain activities on behalf of related companies in high-tax countries e. Expenses for the upkeep or preservation of a building or equipment.

Free access to IBFD Online Tax Glossary – IBFD

The primary types of derivatives include forward contracts, futures, options and swaps. The extent of a person’s beneficial ownership of a particular asset. This edition contains hundreds of new and revised terms, a list of tax courts and their location, and additional languages in the multilingual list of tax terms. According to OECD report, tax havens have the following key characteristics; No or only nominal taxes; Lack of effective exchange of information; Lack of transparency in the operation of the legislative, legal or administrative provisions.

IBFD international tax glossary Author: This can be either an incorporated venture or an unincorporated venture. Usually a combination of property, payroll, turnover, capital invested, manufacturing costs, etc. Also known as hour trading since the transactions are carried out continuously during a day in financial markets worldwide. The report generally consists of a balance sheet, income statement and may include other information as well. 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.


In the classic interest rate swap agreement two parties contract to exchange interest payments based on the same amount of indebtedness of the same maturity and with the same payment dates; one party provides fixed interest rate payments in return for variable rate payments from the other party and vice versa. The OECD model treaty does not allow application of it. Similar Items Related Subjects: The exercise of control by one person over another could enable individuals and corporations to avoid or reduce their tax liability.

A captive insurance company is usually established in a low-tax country. Accurate descriptions of both traditional and more obscure terms. The third party then assumes responsibility for the administration and collection of the debt on the due date for its own account. It denotes a comparable whose data is not disclosed to the public or the taxpayer but known only to the tax authority which is making the transfer pricing adjustment.

An essential feature of such regimes is that they attribute a proportion of the income sheltered in such companies to the shareholder resident in the country concerned. Cancel Forgot your password? The price for the foreign currency is agreed on the day the contract is bought or sold. Portfolio investors may receive different tax relief or other treatment in respect of their dividends under tax treaties from those accorded to other direct investors.

The individual owner is personally liable for all debts of the business. The name field is required. If you do not have an account, register here.