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taxes imposed by governments on divident, interest, and royalty payments to foregin ivnestors |
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consumption tax found in europe and canda |
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generally aim at keeping dmestic gods price competetive with imports |
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indirect taxes reduce pruchasing power in the local market |
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classical tax administration system |
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coproate income taxes on taxable income are levied at the corporate level and the sharehoder level |
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integrated tax administration system |
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corporate and shareholder taxes are integrated so as to reduce or elminate the double taxation of corporate income |
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tax credit/imputation system |
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common variant of the integrated tax system where a tax is levided on corporate income, but part of the tax paid can be trated as a credit against personal income taxes whend diidends are distributed to shareholders |
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another vairant of the integrated tax system, where a lower tax is levied on distriuted earnings than on retained earnings |
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1. no or low taxes on income 2. lack of effective exchang eof information 3. lack of transparency 4. no substantial activities |
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four factors OECD for identifying tax haven |
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exempt from taxation the income of resident corporations generated otuside their borders |
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subsidiary is at a competitive DISADVANTAGE if county relies on indirect ta |
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branch's income immmediately consolidated with that of the parent |
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incrase profits by setting high transfer prices on compnents shipped from subsidiaries in low tax countires |
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comparable unctonrolled pricing resale pricing cost plus pricing other |
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Definition
acceptable arm's length pricing methods |
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