Undue hardship is a condition precedent to the granting of an extension of time to make a tax payment. {code: 'ad_btmslot_a', pubstack: { adUnitName: 'cdo_btmslot', adUnitPath: '/2863368/btmslot' }, mediaTypes: { banner: { sizes: [[300, 250]] } }, { bidder: 'criteo', params: { networkId: 7100, publisherSubId: 'cdo_rightslot2' }}, FISCAL POLICY  -- Part of economic policy which relates to taxation and public expenditure. ONSHORE COMPANY  -- Term sometimes used to denote the converse of offshore company. Upon exercising an option for separate taxation, a husband and wife are treated as separate individuals for the purpose of computing income tax. userSync: { by using transfer pricing) in order to reduce the overall tax liability of the group or corporation. Taxation, imposition of compulsory levies on individuals or entities by governments. { bidder: 'onemobile', params: { dcn: '8a9690ab01717182962182bb50ce0007', pos: 'cdo_mpuslot3_mobile_flex' }}, CREDIT, TAX -- Allowance of deduction from or a direct offset against the amount of tax due as opposed to an offset against income. PREFERRED STOCK  -- See: Preference shares 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. { bidder: 'ix', params: { siteId: '195453', size: [300, 50] }}, LEASEBACK  -- See: Sale and leaseback BROTHER-SISTER CORPORATIONS  -- Two or more companies which are owned and controlled by the same shareholders. { bidder: 'criteo', params: { networkId: 7100, publisherSubId: 'cdo_rightslot' }}, { bidder: 'openx', params: { unit: '539971069', delDomain: 'idm-d.openx.net' }}, { bidder: 'ix', params: { siteId: '195452', size: [336, 280] }}, In EU context, it means one of the legal instruments issued by the competent institutions of the European Union. bids: [{ bidder: 'rubicon', params: { accountId: '17282', siteId: '162036', zoneId: '776160', position: 'atf' }}, SECURITIES  -- Documents providing evidence of a share in the capital of a company (e.g. As part of such analysis, OECD has developed a definition and system of classification of internal taxes, generally followed below. The tax embodied in the price paid for the assets may be credited to the trader over a period of years corresponding to the life of the assets. given up)" under the provisions of the tax incentives. (See: Company) { bidder: 'ix', params: { siteId: '195453', size: [320, 50] }}, googletag.pubads().setTargeting('ad_h', Adomik.hour); { bidder: 'triplelift', params: { inventoryCode: 'Cambridge_SR' }}, It has an especially significant role in international tax matters. { bidder: 'pubmatic', params: { publisherId: '158679', adSlot: 'cdo_mpuslot3' }}]}]; REPATRIATION  -- Individuals and legal entities investing their capital in a foreign country in order to derive income from such capital may wish to transfer this capital or income back to their home country, i.e. The deductions in this part are individually listed, item by item. { bidder: 'onemobile', params: { dcn: '8a9690ab01717182962182bb50ce0007', pos: 'cdo_mpuslot2_mobile_flex' }}, The fixed base provision attributes the right to tax income from independent personal services to the "other" country (i.e. CONSTRUCTIVE OWNERSHIP -- A taxpayer may be considered to own property or stock which he only indirectly owns. SOLE PROPRIETORSHIP  -- Ownership of all of the assets of an unincorporated business by a single individual. {code: 'ad_contentslot_2', pubstack: { adUnitName: 'cdo_mpuslot', adUnitPath: '/2863368/mpuslot' }, mediaTypes: { banner: { sizes: [[300, 250], [320, 100], [320, 50], [300, 50]] } }, { bidder: 'ix', params: { siteId: '195452', size: [336, 280] }}, LIQUIDATION  -- A company in liquidation is a company in the process of being dissolved or wound up, and its assets, if any, after payment of its debts, distributed to the shareholders. The taxable base for resident taxpayers is normally the taxpayer's worldwide net worth, i.e. TREATY ON EUROPEAN UNION (EU)  -- The treaty on European Union was signed on 7 February 1992 and entered into force on 1 November 1993. bids: [{ bidder: 'rubicon', params: { accountId: '17282', siteId: '162050', zoneId: '776338', position: 'btf' }}, FORWARD CONTRACT  -- Contract for the delivery of an amount of asset (e.g. LIMITED (SPECIAL) PARTNER  -- See: Limited partnership syncDelay: 3000 REALIZATION  -- A legal concept referring to a time when rights have become legally receivable or obligations have become legally payable. {code: 'ad_topslot_b', pubstack: { adUnitName: 'cdo_topslot', adUnitPath: '/2863368/topslot' }, mediaTypes: { banner: { sizes: [[728, 90]] } }, var googletag = googletag || {}; In the case of a group of companies it may be important to decide how far the general expenses of management of the group should be charged out to and recovered from the members of the group. { bidder: 'triplelift', params: { inventoryCode: 'Cambridge_MidArticle' }}, { bidder: 'appnexus', params: { placementId: '11654152' }}, MUTUAL AGREEMENT PROCEDURE (MAP)  -- A means through which tax administrations consult to resolve disputes regarding the application of double tax conventions. { bidder: 'appnexus', params: { placementId: '11654150' }}, LUMP-SUM TAXATION  -- The tax laws of some countries allow the tax authorities to levy a fixed amount of taxes on income in certain circumstances which deviates from the normal method of applying a rate to income to ascertain taxes payable. }] gross salaries, wages and other remunerations) paid to his employee without regard to their domicile, family status or other individual circumstances. EQUITY CAPITAL -- A method of financing a business where money is received by the issuance of shares in the enterprise. He also promised not to raise taxes and to give a three-year tax holiday to small businesses with good reputations. {code: 'ad_contentslot_2', pubstack: { adUnitName: 'cdo_mpuslot', adUnitPath: '/2863368/mpuslot' }, mediaTypes: { banner: { sizes: [[300, 250], [320, 100], [320, 50], [300, 50]] } }, REINSURANCE Transfer by a primary insurer to another insurer of all or part of any risk it has accepted in a contract of insurance. iasLog("exclusion label : lcp"); { bidder: 'ix', params: { siteId: '194852', size: [300, 250] }}, TAX BURDEN  -- For public finance purposes the tax burden, or tax ratio, in a country is computed by taking the total tax payments for a particular fiscal year as a fraction or percentage of the Gross National Product (GNP) or national income for that year. { bidder: 'onemobile', params: { dcn: '8a969411017171829a5c82bb4deb000b', pos: 'cdo_btmslot_300x250' }}, { bidder: 'ix', params: { siteId: '195464', size: [300, 600] }}, { bidder: 'pubmatic', params: { publisherId: '158679', adSlot: 'cdo_mpuslot2' }}]}, var googletag = googletag || {}; -Z- FLOW-THROUGH ENTITY  -- See Fiscal transparency Fiscal domicile does not necessarily have the same meaning as domicile. It refers to the period of time a taxpayer spends in each country. ROYALTIES  -- Payments of any kind received as consideration for the use of, or the right to use intellectual property, such as a copyright, patent, trade mark, design or model, plan, secret formula or process. INHERITANCE  -- Real property or personal property that is received by heirs. OUTBOUND TRANSACTION  -- Term which refers to the tax treatment of a country's residents (and perhaps citizens) doing business and investing abroad. { bidder: 'onemobile', params: { dcn: '8a969411017171829a5c82bb4deb000b', pos: 'cdo_mpuslot3_flex' }}, This is a theoretical concept and no country uses it. { bidder: 'sovrn', params: { tagid: '446385' }}, { bidder: 'triplelift', params: { inventoryCode: 'Cambridge_HDX' }}, Low-income person or family would receive a direct subsidy, called a negative income tax. INTERCORPORATE DIVIDENDS  -- Dividends distributed between two companies (domestic or foreign) arising from a shareholding or participation in the capital of the paying company. bids: [{ bidder: 'rubicon', params: { accountId: '17282', siteId: '162036', zoneId: '1666926', position: 'btf' }}, { bidder: 'triplelift', params: { inventoryCode: 'Cambridge_SR' }}, LOSSES  -- The term may broadly be defined as the excess of expenses over revenues for a period, or the excess of the cost of assets over the proceeds when the assets are sold or otherwise disposed of, or abandoned or destroyed. TAX HOME  -- A taxpayer's regular place of business or post of duty, regardless of where the taxpayer a family home. to demand a tax from (a person, business, etc.). A number of countries have adopted special regimes to deal with cross-border reinsurance. PE  -- See: Permanent establishment DISTRIBUTION  -- A payout of cash or property from a corporation to a shareholder. googletag.pubads().setTargeting("cdo_ei", "tax"); VIENNA CONVENTIONS  -- There are three multilateral "Vienna Conventions" which are relevant for taxation purposes. bids: [{ bidder: 'rubicon', params: { accountId: '17282', siteId: '162036', zoneId: '776130', position: 'btf' }},

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