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1
Khavanova, Inna A. "Islamic (Counterpart) Financing: The Russian Experiment and International Tax Agreements." Banking law 1 (January 18, 2024): 28–38. http://dx.doi.org/10.18572/1812-3945-2024-1-28-38.
Повний текст джерелаАнотація:
The article analyzes the provisions of the federal law introducing the rules for conducting an experiment to establish special regulation for Partner financing. The peculiarity of Partner financing is that it is consistent with the principles of Islamic finance (Islamic financial model). The author examines the specifics of the qualification of income from Partner financing instruments for the purposes of tax treaties.
2
Werlauff, Erik. "Taxation of Foreign Foundations in Light of EU Law." European Company Law 13, Issue 1 (January 1, 2016): 7–13. http://dx.doi.org/10.54648/eucl2016002.
Повний текст джерелаАнотація:
In Denmark the qualification for tax purposes of a foreign foundation has so far been decided on the basis purely of national tax law. This article argues that it is necessary to consider European law in the testing because it creates a restriction on the freedom of establishment and capital movement if the foundation is not approved as the ‘beneficial owner’ of the income received by the foundation. Such restriction must be able to be justified on the grounds of compelling reasons, suitability and proportionality.
3
Shinkareva, O. V., and V. A. Vishnevskiy. "Tax accounting of expenses of medical organizations for professional training of employees." Buhuchet v zdravoohranenii (Accounting in Healthcare), no. 3 (March 18, 2023): 37–46. http://dx.doi.org/10.33920/med-17-2303-04.
Повний текст джерелаАнотація:
This article considers the specifics of accounting expenses of medical companies for additional professional training of employees for the purposes of calculating corporate income tax. The authors have studied the provisions of labor and tax legislation on the implementation of the employer’s obligation and the employee’s right to master training and professional retraining programs. The conditions under which the employer as a taxpayer can include the amounts spent on the professional training of employees to reduce the tax base in accordance with article 264 of the Tax Code of the Russian Federation have been determined, which, in its turn, is aimed at matching the qualification level of employees to the changing conditions of its professional activity and social environment as well as at getting new or improving the existing professional competences. The results of the study of economic feasibility and expediency of such training are also presented. Practical examples are given.
4
Sauer, Christian, Rainer Heurung, and Ariane Bresgen. "Germanys Statutory Treatment of Special Payments in Transnational Cases." Intertax 42, Issue 10 (October 1, 2014): 644–52. http://dx.doi.org/10.54648/taxi2014057.
Повний текст джерелаАнотація:
In the field of business taxation, the German and Austrian concepts of co-entrepreneurship (Mitunternehmerschaft) take special positions. Following these concepts, partnership profits are attributed to partner shares and, accordingly, the partners are taxed independently under the transparency or pass-through principle (Transparenzprinzip) based on their respective shares and the special payments they receive from the partnership. Special payments (Sondervergütungen), for instance, interest on a loan granted to the partnership by a partner, are treated as income from commercial business according to domestic law. Therefore, section 50d, paragraph 10, of the Income Tax Act (Einkommensteuergesetz [EStG]) determines that the special payments are treated as a business profit for treaty purposes. As a result, Germany waives the right to tax the partner as a German permanent establishment (PE). In transnational arrangements, the unique German system often results in conflicts of qualification. On this account, our paper points out the consequences resulting from the treatment of special payments. Based on case studies with inbound and outbound investments, we outline the current status of the German treatment of special payments in transnational dealings and summarize future prospects.
5
Pandyak, Igor. "System of taxation of hotel enterprises in Ukraine." Visnyk of the Lviv University. Series Geography, no. 54 (November 26, 2020): 142–49. http://dx.doi.org/10.30970/vgg.2020.54.11828.
Повний текст джерелаАнотація:
The taxation system of hotel enterprises in Ukraine according to their organizational and legal status is analyzed. The influence of the tax system on the organizational and functional characteristics of hotels – staff, specialization, indicators of financial and economic activity, qualification of accountants, financial statements, etc. is revealed. The advantages and disadvantages of the general and simplified tax system in Ukraine are described. Most hotel businesses use a simplified tax system. The connection between the state tax policy in the hotel industry and investment activity is revealed. Taxation is a key point in which the government supports investment-attracting businesses. Support is provided in the form of reduced income tax rates, tax benefits. The state, by not receiving budget revenues, encourages hotel companies to reduce their income tax expenditures to invest more in business and increase profits. It is important, together with the reduction in the tax rate, to use means of influence for the purpose of tax relief. In Ukraine, the tax system does not promote investment in the hotel industry. The mechanism of application of tax privileges in countries known to the tourist specialization is characterized. It has been revealed that the hotel taxation system is one of the key factors of their microeconomic development, financial capacity building, and at the same time an instrument of investment in the hospitality sector of Ukraine. Reducing the profit tax rates of hotel companies from 21% to 18% contributes to improving their financial status, increasing production capacity, and improving service levels. However, such a tool cannot be a guarantee of reinvestment in an enterprise. Targeted tax benefits are considered more effective, for example: significantly reducing or exempting companies by category, type, capacity, location of income tax for a specified period. At the same time, with the reduction of the tax rate, it is necessary to use the means of influence to comply with the subjects of the hotel business with the targeted application of tax benefits. Key words: hotel enterprises, tax system, tax breaks, profit of enterprises, investments, investment climate.
6
Tangian, Andranik. "Decent work: indexing European working conditions and imposing workplace tax." Transfer: European Review of Labour and Research 15, no. 3-4 (August 2009): 527–56. http://dx.doi.org/10.1177/10242589090150031801.
Повний текст джерелаАнотація:
This article indexes working conditions using data from the Fourth European Working Conditions Survey 2005 for three purposes. (1) Benchmarking countries and social groups. This reveals poor qualification and career opportunities, and modest incomes. Atypical workers have less advantageous working conditions than those in permanent full-time jobs. This shows that Europe is still far from creating ‘better jobs’ as advocated in the Lisbon agenda. (2) Analysing the flexicurity concept as proposed by the European Commission. Our study disproves the assertion that European workers are less interested in remaining with the same employer but need more flexibility combined with ‘upward mobility’ and lifelong learning. Moreover, Europe has a shortage of training possibilities and workers demonstrate latent resistance to learning. The basis for the Commission's promotion of flexicurity would thus seem questionable. (3) Proposal of a workplace tax for bad working conditions. As with ‘green taxes’, the workplace tax would encourage employers to improve working conditions. Indexing individual working conditions with reference to a checklist, as developed in the article, could be a prototype for measuring ‘social pollution’ to determine the amount of workplace tax.
7
Sentsova (Karaseva), M. V. "The legal qualification of transactions for tax purposes." Russian Journal of Legal Studies 3, no. 3 (September 15, 2016): 111–16. http://dx.doi.org/10.17816/rjls18173.
Повний текст джерелаАнотація:
In the clause it is underlined that quite often the rights of tax payer are demanded by protection in connection with wrong qualification of the transactions made by the tax payer. The drawbacks of the qualifications take place in activity of tax departments and courts.
8
Kulicki, Jacek. "Zasady opodatkowania dochodów i obrotów ze sprzedaży produktów wytwarzanych w gospodarstwach rolnych." Zeszyty Prawnicze Biura Analiz Sejmowych 1, no. 69 (2021): 189–215. http://dx.doi.org/10.31268/zpbas.2021.16.
Повний текст джерелаАнотація:
The analysis of the applicable regulations leads to the conclusion that the system of taxation of farmers’ income is complex. The author points out different definitions of agricultural activity for the purposes of income tax and value added tax. The legislator makes the classification of agricultural income among individual sources of income for the purposes of personal income tax dependent on whether they are processed or unprocessed products and on the method of their processing. The differences in the treatment of farmers’ revenues for the purposes of income tax overlap with the tax obligations with regard to value added tax and excise tax.
9
Tiley, John. "Income Tax—Purposes and Trading Transactions." Cambridge Law Journal 50, no. 3 (November 1991): 416–18. http://dx.doi.org/10.1017/s0008197300016159.
Повний текст джерела
10
Van Schalkwyk, Linda, and Rudie Nel. "Non-executive directors: Employees or independent contractors for both income tax and employees’ tax purposes?" Journal of Economic and Financial Sciences 6, no. 2 (July 31, 2013): 401–20. http://dx.doi.org/10.4102/jef.v6i2.267.
Повний текст джерелаАнотація:
The concept ‘independent contractor’ is one of the more contentious concepts contained in the Fourth Schedule to the Income Tax Act 58 of 1962, as amended. The classification of a person rendering services as either an ‘employee’ or an ‘independent contractor’ is relevant for both income tax and employees’ tax purposes. The objective of this article is to determine whether non-executive directors (both resident and non-resident) are employees or independent contractors for both purposes, respectively. A comprehensive literature review was done in which the meaning of the concepts ‘non-executive director’ and ‘independent contractor’ was discussed in order to gather information needed for the classification. The statutory and common law tests were then applied to determine the classification of non-executive directors as independent contractors. The conclusion reached is that resident non-executive directors could qualify as ‘independent contractors’ for employees’ tax and income tax purposes. Non-resident non-executive directors of companies are ‘employees’ for employees’ tax purposes and ‘independent contractors’ for income tax purposes.
11
Cipollini, Claudio. "Article: Crypto Staking Taxation Across Selected Countries: A Critical Evaluation." Intertax 52, Issue 2 (February 1, 2024): 118–38. http://dx.doi.org/10.54648/taxi2024019.
Повний текст джерелаАнотація:
The objective of this article is to evaluate countries’ approaches to the taxation of crypto staking by testing the consistency of current domestic rules and guidance against the technological substance of the same phenomenon. After the outline of the economics of crypto staking, the author provides evidence of the debate in tax literature and the regulatory landscape across selected countries. Subsequently, the research explores the technology features of staking and its fundamental variables of legal characterization, income qualification, and timing and value of income recognition. This way, the interdisciplinary methodology aims to outline a model of taxation reflecting the technological substance of crypto staking and test it against the current tax framework at the domestic level. The results of the analysis process show that the approach to the taxation of staking rewards does not ensure consistency with the technological substance in all of the selected countries. National tax authorities rely more on policy considerations aimed at maximizing revenue collection when developing guidance in the field than on the idea of coherent tax treatment in accordance with the technological substance and the legal characterization of the different types of staking activities. Tax & Technology, Blockchain, Cryptocurrencies, Proof-of-stake, Staking rewards, Direct staking, Indirect staking, Legal characterization, Income qualification, Time of income recognition
12
de Leeuw, Arianne, and Arco C. P. Bobeldijk. "Dutch Corporate Income Tax and Dividend Withholding Tax Treatment of Separated Private Estates." Intertax 43, Issue 12 (December 1, 2015): 844–50. http://dx.doi.org/10.54648/taxi2015077.
Повний текст джерелаАнотація:
Since 2010, the Netherlands have (anti-abuse) regulations regarding the fiscal treatment of so-called ‘separated private estates’, with as a main rule the attribution of assets and income for personal income tax and gift and inheritance tax purposes. The authors discuss the consequences these regulations have for the corporate income tax and dividend withholding tax.
13
Artemov, N. M., and V. V. Golenev. "Determination of the actual tax liability for personal income tax: law enforcement analysis." Law Enforcement Review 6, no. 2 (June 21, 2022): 93–105. http://dx.doi.org/10.52468/2542-1514.2022.6(2).93-105.
Повний текст джерелаАнотація:
The subject. Currently, the courts are actively using a new term - "valid tax liability", or "the actual amount of tax liabilities". This term is the result of the activities of judicial authorities, however, judicial practice on determining the actual tax liability for personal income tax is only being formed and is unstable. Therefore, the subject of the study of this article is a comprehensive analysis of law enforcement practice in the field of determining the actual tax liability of individuals for personal income tax.Purpose of the study is to dare to solve the enforcement problems that arise when determining the actual tax liability of individuals for personal income tax.The methodology. The authors uses the formally legal interpretation of Russian legislation, comparative analysis of Russian and European literature as regards the determination of a valid tax liability.The main results, scope of application. The authors analyzed the concept of "valid tax liability", and also studied the problems of determining the actual tax liability in the context of the law enforcement practice of the Supreme Court of the Russian Federation. Based on law enforcement practice, the main problems in determining the actual tax liability are highlighted, to which the authors attribute the incorrect qualification of the object of taxation, the incorrect qualification of the nature of the taxpayer's activity and its status, as well as the incorrect determination of the taxpayer's tax base. The article also touches on the main problems in the reimbursement of the amount of overpaid personal income tax.Conclusions. When determining the taxpayer's actual tax obligation to pay personal income tax, the tax authorities are guided by a "pro-budget" goal, seeking to increase the tax base due to incorrect qualification of the taxable object, the status of the taxpayer, or questioning the nature of its activities, which leads to the formation of arrears and forms the composition of an administrative offense.In an effort to restore their violated rights, an honest taxpayer goes to court for protection, where, unfortunately, in the vast majority of cases, they face the formal approach of the courts, which do not reveal either the economic essence of the dispute or properly consider the circumstances of a particular case. Taking into account the above circumstances, the authors draw conclusions about the existence of legal gaps in the system of Russian law in the field of taxation, which they propose to fill by fixing the concept of "valid tax obligation" in the relevant Resolution of the Plenum of the Supreme Court of the Russian Federation. As an example of such replenishment, the authors propose to supplement paragraph 7 of the Resolution of the Plenum of the Supreme Commercial Court of the Russian Federation of October 12, 2006 No. 53 "On the assessment by arbitration courts of the validity of the taxpayer's receipt of tax benefits", indicating the need to establish a valid tax obligation of the taxpayer, including personal income tax.
14
Buursma, Jogchum, and Xavier Auerbach. "The Netherlands: New Legislation Regarding the Taxation of Trusts." Intertax 38, Issue 8/9 (August 1, 2010): 465–71. http://dx.doi.org/10.54648/taxi2010049.
Повний текст джерелаАнотація:
With effect from 1 January 2010, the Dutch Inheritance and Gift Tax Act 1956 (IGTA) has been revised. The Netherlands Ministry of Finance identified the taxation of existing trust schemes and schemes that make use of irrevocable discretionary trusts allowing the avoidance of income tax and/or inheritance or gift tax in particular, as one of the most important objectives of the revision of the IGTA. The basic idea of the new legislation is that irrevocable and discretionary trust schemes are ignored for tax purposes (both for personal income tax and for IGTA purposes) and their income and assets attributed to the individuals involved.
15
Sekhon, Shailinder. "Indian Agricultural Income Lessens the Income Tax Burden: A Fiscal Illusion." VISION: Journal of Indian Taxation 9, no. 2 (2022): 70–83. http://dx.doi.org/10.17492/jpi.vision.v9i2.922205.
Повний текст джерелаАнотація:
The Indian income tax law spares the Indian agricultural income from payment of income tax because charging tax on agriculture produce or keeping it exempted is a state subject. But from the financial year 1974-75 by an amendment the Union government increased the tax burden on the taxpayer having both agricultural as well as non-agricultural income. This system was executed as an enforcement of the provisions of “Partial Integration of agricultural income with non-agricultural income” for tax rate purposes. As a result taxpayer bears more tax burden on his non-agricultural income due to his agricultural income which otherwise comes under the category of exempted incomes. The paper highlights the fact that how a fiscal illusion is created by increasing the tax rates. State governments need to raise this issue at appropriate platforms to question why government is collecting additional tax revenue against the agricultural income which is the state subject.
16
Stara, Nancy J., and Brad Cripe. "State Law: The Foundation for Federal Tax Law." ATA Journal of Legal Tax Research 2, no. 1 (January 1, 2004): 26–39. http://dx.doi.org/10.2308/jltr.2004.2.1.26.
Повний текст джерелаАнотація:
To determine if property exists for purposes of federal income tax law, a bifurcated analysis is needed because state law creates the legal rights and interest associated with property, but federal income tax law determines if the rights or interest are sufficient to create property for a specific tax purpose. Recent court cases and Internal Revenue Service rulings are examined to clarify: • What legal rights and interest are held by a taxpayer under state law, and • Whether those rights and interest are property for purposes of federal income tax law. Although state law provides the foundation for federal income tax law, B. Bittker has noted that its consideration “rarely rises to conscious level.” This article reviews the interrelationship of state and federal law in defining property rights and interest—and, in doing so, creates the conscious awareness needed for effective tax planning.
17
Nel, Rudie. "Depreciation allowances for tax purposes in periods of less than a year." De Jure 55, no. 1 (April 17, 2023): 173–83. http://dx.doi.org/10.17159/2225-7160/2022/v55a11.
Повний текст джерелаАнотація:
In tax legislation, a depreciation allowance is applied in three provisions and results in a reduction of taxable amounts. A depreciation allowance is calculated for the period an employer owned a vehicle prior to granting the right of use to an employee (paragraph 7(1) of the Seventh Schedule to the Income Tax Act and section 10(13) of the Value-Added Tax Act) or the period an asset was leased prior to acquisition by the lessee (section 8(5)(bB) of the Income Tax Act). Both periods could consist of or include a period of less than a year. The uncertainty of interest in this article is whether a depreciation allowance should be disregarded or not when a period of less than a year is concerned. The tax implications, wording, and context of the three tax provisions were considered with due regard for the limited current guidance offered by the SARS. The findings of this article suggest that a taxpayer following current guidance in the application of all three tax provisions would not be correct. In line with current guidance relating to paragraph 7(1) of the Seventh Schedule to the Income Tax Act, the depreciation allowance contemplated in section 10(13) of the Value-Added Tax Act should disregard a period of less than a year. Contrary to current guidance, the different context of the depreciation allowance contemplated in section 8(5)(bB) of the Income Tax Act is argued as affording the opportunity to apply the depreciation allowance when a period of less than a year is concerned. A depreciation allowance applied for a period of less than a year would result in a lower recoupment for inclusion in taxable income for normal tax purposes and, as a result, argued as beneficial to taxpayers.
18
Попов and Alexey Popov. "Tax Accounting of Securities Transactions: Features, Problems and Solutions." Economics 4, no. 3 (June 17, 2016): 21–24. http://dx.doi.org/10.12737/18959.
Повний текст джерелаАнотація:
The article is devoted to the peculiarities of the recognition and measurement
of income and expenses from operations with securities in order to form the tax
base for income tax. Regulatory concept and types of securities are considered.
The general provisions of the formation of financial results from operations with
securities for tax purposes are formulated. The features of the valuation
of securities at their initial recognition the acquisition cost is expressed in rubles
and foreign currency. Principles of income and cost estimates for listed and
unlisted securities organized market are marked. The questions of calculation
of income and expenses for tax purposes are discussed when the transaction
with securities made on the organized market and outside it. The features of the
tax account of losses on securities transactions are considered. Perspective
directions for improvement of tax accounting operations with securities are
formulated.
19
Putri, Victoria Pasari. "Analysis of tax law on income tax for construction services business." Requisitoire Law Enforcement 14, no. 2 (January 30, 2023): 33–38. http://dx.doi.org/10.59651/relae.v14i2.94.
Повний текст джерелаАнотація:
This study aims to analyze the implementation of the provisions Article 4 paragraph (2) letter d of the Income Tax Law and Article 23 paragraph (1) letter c number 2 of the Income Tax Law regarding the withholding of income tax for construction services businesses and the application of deductions to Article 23 paragraph (1) letter c number 2 of the Income Tax Law regarding business income tax deductions construction service? This research was conducted at CV. Mandala Putra and Office Services, counseling, and tax consulting in North Toraja Regency. The method used in this study was field research where data collection was carried out by interviewing and taking into account the books and applicable laws and regulations. The data obtained were then analyzed qualitatively and presented descriptively. The results of this study indicate: 1). Implementation of the provisions of Article 4 paragraph (2) letter d and Article 23 paragraph (1) letter c number 2 of the Income Tax Law related to the withholding of income tax for construction services businesses, namely the existence of a qualification requirement intended in the form of a business entity certificate issued by a construction service development agency for tax imposition which are final due to certificates and non-certified business entities are subject to non-final tax 2). In applying the tax of Article 23 paragraph (1) letter c number 2 in the construction service business, it is carried out by the cutting party by first making a billing ID, then paying it through a Perception Bank that has been approved by the Ministry of Finance. The payment due date is the 10th, one month after the month the income tax is due. After that Reporting is done by the cutting party by filling out Periodic Income Tax Return Article 23, then you can report it through the online tax report feature or free efiling on Online Tax. The reporting due date is the 20th, a month after the month the income tax is due.
20
Schmidt, Dennis. "Ministerial Tax Issues: On Wingo and a Prayer." ATA Journal of Legal Tax Research 6, no. 1 (January 1, 2008): 78–93. http://dx.doi.org/10.2308/jltr.2008.6.1.78.
Повний текст джерелаАнотація:
Special tax provisions apply to individuals who qualify as “ministers.” For example, they are allowed to exclude certain housing allowances from gross income and are exempt from federal tax withholdings. Most ministers are classified as employees, yet courts have also held some of them to be independent contractors. Minister-employees have a dual tax status. They are considered employees for income reporting, fringe benefit, and expense deducting purposes but are treated as self-employed persons for social security purposes. Because of their intricacies and material financial impact, special provisions that apply to ministers demand thorough legal analysis and careful tax planning. This article analyzes several key tax issues that confront ministers and provides a variety of tax planning ideas.
21
Semenova, Galina N. "INCOME TAX AS A TOOL TO STIMULATE INNOVATIVE AND INVESTMENT ACTIVITY IN RUSSIA." EKONOMIKA I UPRAVLENIE: PROBLEMY, RESHENIYA 5/2, no. 137 (2023): 235–43. http://dx.doi.org/10.36871/ek.up.p.r.2023.05.02.035.
Повний текст джерелаАнотація:
In modern conditions, income tax is becoming an increasingly important tool for regulating the Russian economy. The tax policy in the field of corporate income taxation should stimulate the development of innovation and investment activity, which is a key factor in increasing the competitiveness of the national economy and ensuring its sustainable growth. First of all, it should be noted that income tax directly affects the financial capabilities of enterprises for innovation and investment activities. Lower income tax rates, especially for small and medium-sized enterprises, can stimulate their investment and innovation activity, as this will allow them to allocate more funds for these purposes. In addition, the income tax can also help attract foreign investment in the Russian economy. High income tax rates may discourage potential investors, while lowering income tax rates and creating tax incentives for investors may attract additional investment.
22
Brink, Sophia. "An evaluation of the income tax treatment of client loyalty programme transactions by South African suppliers." Journal of Economic and Financial Sciences 8, no. 1 (April 30, 2015): 145–64. http://dx.doi.org/10.4102/jef.v8i1.88.
Повний текст джерелаАнотація:
The popularity of client loyalty programmes has increased drastically over the past few years, with more than 100 suppliers in South Africa currently making use of them. Despite the fact that client loyalty programmes have been prevalent in South Africa since the 1980s, the South African Revenue Service has issued no specific guidance on the income tax treatment of client loyalty programme transactions. The main objective of the research was to determine whether South African client loyalty programme suppliers treat client loyalty programme transactions correctly for income tax purposes. In order to meet this objective, available local and international literature were analysed to determine the proposed income tax treatment of a client loyalty programme transaction expenditure incurred by supplier for purposes of the client loyalty programme. The proposed correct income tax treatment was compared with a survey circulated to a population of client loyalty programme suppliers in South Africa. The comparison indicated that in practice the Income Tax Act No. 58 of 1962 is treated differently from the proposed treatment. This incorrect tax treatment could result in possible financial loss to the client loyalty programme supplier as taxpayer.
23
Shevlin, Terry, Tanya Y. H. Tang, and Ryan J. Wilson. "Domestic Income Shifting by Chinese Listed Firms." Journal of the American Taxation Association 34, no. 1 (January 1, 2012): 1–29. http://dx.doi.org/10.2308/atax-10150.
Повний текст джерелаАнотація:
ABSTRACT To encourage economic development in specific regions and industries, the Chinese Central and local governments offer a series of corporate income tax incentives (tax exemptions, reduced tax rates, tax holidays, and tax refunds). In China, parent and subsidiary companies are consolidated for financial reporting, but not for tax purposes. We take advantage of a unique disclosure in the tax footnotes of Chinese listed firms to examine income shifting among consolidated group members in response to these incentives. We find that intangible-intensive groups (“firms”), and firms concerned with meeting minimum earnings thresholds to issue equity, shift greater amounts of income. We find no evidence that high concentrations of either Central or local government ownership affect the level of income shifting.
24
Castro, Leonardo Freitas de Moraes e., and Alexandre Luiz Moraes do Rêgo Monteiro. "Qualification of Services Under Double Tax Treaties in Brazil: Open Issues After Iberdrola Case." Intertax 45, Issue 1 (January 1, 2017): 54–66. http://dx.doi.org/10.54648/taxi2017005.
Повний текст джерелаАнотація:
This article analyses the discussion regarding the tax assessment of Withholding Income Tax (WHT) on service fees paid from Brazil to other countries that have entered into a Double Tax Treaty with it. Mainly, after the judicial precedent known as Iberdrola case, the Brazilian Superior Court of Justice (STJ) left without analysis several issues that may play a role against future discussions on the qualification of such income under the treaty, namely the possible application of Article 12 and Article 14 to such stream of income. Although the Iberdrola case was favourable to taxpayers, since it applied Article 7 to prevent Brazil from levying the WHT of service payments from Brazil to Spain, it has failed to discuss if the technical service fees would be qualified under Royalties – due to specific protocol stating so – or Independent Personal Services – due to specific wording of the Double Tax Treaties (DTTs) entered into by Brazil. Due to this short-sided view of Brazilian courts, taxpayer should be aware that the precedents on the matter so far left out important issues to be examined, which can be crucial in case of a shift of position on the subject, in the near future.
25
Steuerle, C. Eugene. "Policy Watch: Tax Credits for Low-Income Workers with Children." Journal of Economic Perspectives 4, no. 3 (August 1, 1990): 201–12. http://dx.doi.org/10.1257/jep.4.3.201.
Повний текст джерелаАнотація:
The most important tax credits available to low-income households with children are the earned income tax credit (EITC), the child tax credit, and the child and dependent care tax credit (hereafter, child-care credit). Only the EITC and the child-care credit exist in current law in the United States. This note will discuss some equity and efficiency implications of four commonly stated purposes of these credits within the tax/transfer system: greater progressivity, adjustments for the presence of children, greater choice among goods and services, and greater work incentives for low-income individuals.
26
Shon, John, and Stanley Veliotis. "Is There a December Effect? Strategic Prepayments of Deductible State Income Tax." Journal of the American Taxation Association 32, no. 2 (September 1, 2010): 53–71. http://dx.doi.org/10.2308/jata.2010.32.2.53.
Повний текст джерелаАнотація:
ABSTRACT: Individuals’ state income tax payments are deductible in the year paid for federal income tax purposes. This study investigates whether, and to what extent, individuals implement federal tax planning by prepaying state estimated income taxes before year-end, even though those payments are not due until January 15. Based on a study of 34 states’ aggregate data on estimated income tax receipts from individuals, we find strong evidence of this effect. We also find that this effect is increasing with the cost of state income tax payments. The results suggest that individual taxpayers take steps to reduce taxes by shifting deductions from one year to an earlier year and/or exploit the time value of money provided by accelerating federal tax savings by one year.
27
Brazelton, Julia K., Caroline D. Strobel, and David Ryan. "Equity: The Effects Of Tax Reform On Progressivity Features Of The Tax Structure." Journal of Applied Business Research (JABR) 7, no. 4 (October 18, 2011): 9. http://dx.doi.org/10.19030/jabr.v7i4.6198.
Повний текст джерелаАнотація:
The impact of the Tax Reform Act of 1986 (TRA86) on equity is examined using a simulation program and statistical analysis. Specifically, a sample of tax returns was manipulated to calculate taxable income for 1987 and 1988. The results were then compared to determine the degree to which effective and average tax rates changed within discrete income levels. Using both t-test and z statistics, the results confirm the hypothesis that the degree of progressivity has been affected by TRA86. A graphic analysis illustrates this change at various income levels for both the average and effective tax rates. These findings are significant for tax policy decision purposes.
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Toshmatov, Shukhrat A., Zafarjon A. Abdullaev, and Zarif O. Ahrorov. "Influence of Corporate Income Tax to Loan Loss Provision: Evidence from Uzbekistan." Journal of Tax Reform 8, no. 3 (2022): 236–50. http://dx.doi.org/10.15826/jtr.2022.8.3.119.
Повний текст джерелаАнотація:
This article is devoted to the analysis of the impact of corporate income tax on compulsory reserves created by commercial banks for possible loan loss provision. In the majority of countries banks are required to create compulsory reserves for potential loan loss provisions, and the corporate tax regime applies tax deductions to these compulsory reserves. The corporate tax system facilitates timely coverage of potential loan loss provision. In addition, corporate taxation is an essential factor in the transparency of banks’ financial statements. The research has revealed that reserves for potential loan loss provision are used primarily for profit regulator purposes, not to regulate capital. This implies that when deducting the amount of total reserves for tax purposes of banks the loan loss provision is positively related to the corporate income tax rate. The analysis of the selected commercial banks has confirmed that the impact of corporate income tax is more significant for the timely admitting potential loan loss provision when deducting general reserves from the tax base, mainly for the purpose of taxing banks’ profits. According to the results, an increase in the tax rate by an average of 1% could lead to an increase in the amount of required loan loss provision by 3.9%. This means that when total reserves are deducted for tax purposes, the underlying hypotheses that compulsory reserves for loan loss provisions are positively correlated with the corporate income tax rate and that the amount of loss reserves is increased at the income tax rate have been confirmed. In general, the following aspects are crucially important in the taxation of profits of commercial banks: which method is more convenient for loan loss provision (write-offs or formation of reserves); entire or partial compliance between the taxation and regulation of reserves for loan loss provision; imposing restrictions on the application of tax deductions to reserves for possible loan loss provisions.
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Lim, Setiadi Alim. "Earning Management dan Deferred Tax." BIP's JURNAL BISNIS PERSPEKTIF 2, no. 2 (July 30, 2010): 109–17. http://dx.doi.org/10.37477/bip.v2i2.282.
Повний текст джерелаАнотація:
Corporate managers often face conflicting interest when they report their earning for financial and tax purposes. On one side, managers desire to increase earnings that will be reported to creditors, shareholders and other external users. But on other side, managers also desire to decrease taxable income that will be reported to tax authorities. Managers can achieve these two goals by manipulating earnings upward for financial reporting but not for tax reporting. So managers don't pay income taxes on the upward earnings. In long term this will increase gap between book-tax income differences and effect deferred tax account.
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Lim, Setiadi Alim. "Earning Management dan Deferred Tax." BIP's JURNAL BISNIS PERSPEKTIF 2, no. 2 (July 30, 2010): 109–17. http://dx.doi.org/10.37477/bip.v2i2.282.
Повний текст джерелаАнотація:
Corporate managers often face conflicting interest when they report their earning for financial and tax purposes. On one side, managers desire to increase earnings that will be reported to creditors, shareholders and other external users. But on other side, managers also desire to decrease taxable income that will be reported to tax authorities. Managers can achieve these two goals by manipulating earnings upward for financial reporting but not for tax reporting. So managers don't pay income taxes on the upward earnings. In long term this will increase gap between book-tax income differences and effect deferred tax account.
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Choi, Won-Wook, and Hyun-Ah Lee. "Management Of Accrual Components In Response To Corporate Income Tax Rate Changes: Evidence From Korea." Journal of Applied Business Research (JABR) 29, no. 5 (August 28, 2013): 1421. http://dx.doi.org/10.19030/jabr.v29i5.8024.
Повний текст джерелаАнотація:
Changes in the statutory corporate income tax rate provide firms with an opportunity to reduce their tax burden by shifting their taxable income from higher to lower tax rate years. One negative consequence of shifting taxable income across years is higher variation in book income for financial reporting purposes. Taxable income and book income are closely related in most countries, and, in general, reporting volatile book income across years is not a favorable signal to investors. This study investigates how firms shift taxable income and concurrently mitigate book income fluctuation by managing accrual components separately when the statutory income tax rate changes. Unlike prior studies, we decompose discretionary accruals into two components and examine distinctive patterns of accrual management in Korea, where book-tax conformity is high and aggressive tax avoidance is restricted. We find that firms manage book-tax accruals for taxable income shifting and manage book-only accruals to mitigate book income fluctuation. Furthermore, we find the extent of book-tax and book-only accruals management varies depending on the firms tax and financial reporting costs. The results of this study provide clear and compelling evidence of firms opportunistic accrual management behavior in response to statutory tax rate reduction.
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Schwibinger, Stefan. "Developing a Uniform Understanding of Income Classification: Everyones Business? A Review of Business Income and the Criterion of Asset Management in Tax Treaty Interpretation." Intertax 47, Issue 1 (January 1, 2019): 7–23. http://dx.doi.org/10.54648/taxi2019002.
Повний текст джерелаАнотація:
Conflicts of qualification under tax treaties may result from the lack of a clear borderline between business income and investment income, with potential remedies existing to resolve this problem. To analyse the problem, this article first highlights the general roots of the distinction between different income categories and then specifically addresses the categories of business income and investment income by initially outlining their general characteristics and then reviewing their different understanding in a tax treaty context for selected countries. The issue is especially relevant for borderline cases, in which specific and unique case law has developed in each jurisdiction with respect to asset management that may cause conflicts of classification in cases where a tax treaty is applied. The article then introduces and evaluates two approaches that aim to resolve conflicts of classification, namely the principle of common interpretation and the new approach to Article 23A/B OECD-MC, with regard to their applicability in the field of income classification. The approaches are then applied to case studies, followed by a discussion of the results and potential limitations.
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Ofiarski, Zbigniew. "New Income Tax Reliefs for Donations Made by Taxpayers for Purposes Related to Combating the Effects of the COVID-19 Pandemic." Białostockie Studia Prawnicze 26, no. 4 (November 26, 2021): 121–38. http://dx.doi.org/10.15290/bsp.2021.26.04.08.
Повний текст джерелаАнотація:
Abstract In an effort to limit the effects of the COVID-19 epidemic determined by restrictions in economic activity and various areas of social activity, the catalogue of preventive actions was expanded by tax and legal instruments in the form of income tax reliefs inclining taxpayers to certain behaviours. The reliefs entitle taxpayers to deduct the value of donations made for the purposes of counteracting COVID-19 from the tax base. Two types of such donations have been distinguished, i.e., donations for entities participating in the treatment of infected persons and donations for educational institutions providing remote education. The aim of this article is to establish the premises justifying the claim that the tax reliefs for donations made by income tax payers are autonomous in relation to other tax preferences available to taxpayers making donations for other socially useful purposes. The hypothesis about the ad hoc and temporary nature of these tax reliefs has been verified as true, and the dominance of the motivating and stimulating function over their fiscal function has been demonstrated. Symmetrical solutions have been identified in the legal structure of the subject tax reliefs, as the donor uses a deduction from the tax base, while the recipient does not include the accepted donation in their income. The study uses the legal-dogmatic method and, in addition, the empirical analytical method to present the jurisprudence of courts in the field of applying tax reliefs due to donations made by income tax payers.
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Aprilia, Fatma Yunita, Luluk Desva Fitriah, and Gideon Setyo Budiwitjaksono. "ANALISIS REVALUASI ASET DALAM LAPORAN KEUANGAN PT PLN TAHUN 2021." Jurnal Manajemen, Bisnis dan Kewirausahaan 2, no. 3 (December 27, 2022): 74–81. http://dx.doi.org/10.55606/jumbiku.v2i3.508.
Повний текст джерелаАнотація:
Revaluation of fixed assets is a methode to revaluate company’s fixed assets to reflect the market value. Revaluation of assets can be done for accounting purposes, tax purposes, or accounting and tax purposes. Revaluation of fixed assets for tax purposes is regulated in the Regulation of the Minister of Finance No. 191/PMK.010/2015. The purpose of this study is to analyze the taxes that must be paid in 2021 as a result of the asset revaluation practice carried out by PT PLN (Persero). This study used a descriptive method with a qualitative approach. The object of this research is PT Perusahaan Listrik Negara (Persero). Data used for this research are 2021 financial statements of PT Perusahaan Listrik Negara (Persero) from its official website. The result of this study indicate that the revaluation of fixed assets for tax purpose by PT PLN in 2021 can reduce the totals of assets and its net income, furthermore the revaluation of fixed assets does not affect the income tax for the year after revaluation due to the loss of revaluation of fixed assets by PT PLN in 2021.
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Raicevic, Bozidar, Brankica Gagic, and Danijel Pantic. "System and tax policy and population policy." Stanovnistvo 36, no. 1-2 (1998): 81–104. http://dx.doi.org/10.2298/stnv9802081r.
Повний текст джерелаАнотація:
System and tax policy may be used for numerous purposes. That is, especially, the case with contemporary tax systems which are, among other features, based at the synthetic (global) taxation of the economic capacity of the natural persons. Besides the basic, fiscal, many other goals, may be reached through the taxation, including those which fall in the scope of the population policy. In this paper, modern tendencies have been analysed in achieving the goals of the population policy, which provide solutions in respect of the following tax instruments: personal income tax, corporate income tax, property tax and turnover tax. It has been emphasized that relatively numerous and differentiated possibilities exist in respect of the annual personal income tax and far less, with the other forms of taxation.
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Antolis, Michael Lianwar, Ida Ayu Putu Widiati, and I. Putu Gede Seputra. "Pengenaan Pajak Penghasilan Terhadap Pelaku Usaha Jasa Promosi Melalui Media Sosial." Jurnal Interpretasi Hukum 2, no. 3 (November 24, 2021): 468–72. http://dx.doi.org/10.22225/juinhum.2.3.4121.468-472.
Повний текст джерелаАнотація:
Income tax is a tax imposed on individuals/business entities on income earned in the tax year. Promotional service business actors are tax subjects who earn income that exceeds the non-taxable income and the income is obtained from activities promoting goods or services through social media, such as Instagram, YouTube, WhatsApp or other types of social media. The purposes of this study are to examine the regulation of income tax in promotional services business activities through social media as well as the mechanism for collecting income taxes against business actors in promotional services through social media. This study uses normative legal research methods, with legal materials consisting of primary legal materials and secondary legal materials. The collection of legal materials in this study was carried out by the recording method. The legal material analysis method used is argumentative technique. The result of the study shows that the regulation of income tax in promotional service business activities through social media, in this case YouTubers or Celebrities, is subject to income tax for those whose income exceeds Non-Taxable Income (PTKP) based on the Regulation of the Director General of Taxes Number PER-17/PJ/2015.
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Kharin, Alexander K. "ANTI-HYBRID MISMATCH PROVISIONS OF THE FOREIGN TAX LEGISLATIONS AND THEIR COMPLIANCE WITH THE TAX CERTAINTY PRINCIPLE." Ser-11_2023 64, no. 4, 2023 (November 8, 2023): 53–68. http://dx.doi.org/10.55959/msu0130-0113-11-64-4-4.
Повний текст джерелаАнотація:
Hybrid mismatch arrangements are means of structuring cross-border transactions which result into double taxation or double nontaxation due to differences in the legal qualification of the taxpayer’s status or the legal qualification of the type of income. Hybrid mismatches arise due to imperfection of legislative techniques and are often accidental, but in some cases hybrid mismatch arrangements act as a way of committing tax offenses, leading to base erosion and profit shifting. The key provisions against the intentional use of hybrid mechanisms aimed at tax avoidance are being specified at the level of national legislations. One of the problems arising out of such norms’ adoption is concluded in providing them with compliance to tax certainty principle, which acts as a guarantee of tax legislation application in accordance with the content of public interest laid down into them, and as the means of protecting the taxpayers’ reasonable expectations at the stage of law enforcement. This article analyzes the existing antihybrid mismatch provisions of the certain foreign tax legislations (on the examples of the United States of America, of the United Kingdom and of the members of the European Union) for their compliance with the tax certainty principle.
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McMahon, Stephanie Hunter. "To Save State Residents: States' Use of Community Property for Federal Tax Reduction, 1939–1947." Law and History Review 27, no. 3 (2009): 585–625. http://dx.doi.org/10.1017/s0738248000003916.
Повний текст джерелаАнотація:
In 1939, at the end of almost two decades of statewide want and despair, Oklahoma adopted the community property system “to save state residents on their federal income tax.” Between 1939 and 1947, Oklahoma and four other states openly and unabashedly exploited the Supreme Court's creation of what amounted to a tax loophole for the nation's wealthy; several more states seriously considered doing the same. In 1930, the Court had ruled that the community marital property regime of eight western states permitted their married couples to split family income between spouses, so that each spouse reported half of that income for federal income tax purposes. As a result of the federal government's progressive income tax bracket structure, in most cases this split meant that more of the family's income would be taxed in lower tax brackets. Thus, a property regime that was purely a creation of state law had the effect of reducing residents' federal tax obligations.
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Khoruzhy, L. I., Yu N. Katkov, R. V. Kostina, A. A. Romanova, and Yu A. Myrksina. "Methodological approaches to the formation of income and expense accounting registers for tax purposes." Buhuchet v sel'skom hozjajstve (Accounting in Agriculture), no. 3 (February 21, 2022): 236–45. http://dx.doi.org/10.33920/sel-11-2203-05.
Повний текст джерелаАнотація:
The article analyzes the main aspects of the problem and promising approaches to accounting for income and expenses when determining the object of taxation for agricultural producers under a special tax regime; the main differences in the accounting of income and expenses in determining the object of taxation for agricultural producers and for accounting purposes are studied and the main correspondence of accounting accounts on the reflection of income and expenses in the conditions of the domestic agro-industrial complex, in particular for agricultural producers using a special tax regime, is proposed.
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Oesterhelt, Stefan, and Reto Heuberger. "Collective Investment Vehicles in International Tax Law: The Swiss Perspective." Intertax 38, Issue 1 (January 1, 2010): 31–37. http://dx.doi.org/10.54648/taxi2010003.
Повний текст джерелаАнотація:
With the Collective Investment Act Switzerland has introduced new types of investment funds, that is, the Société d’investissement à capital variable (SICAV), the limited partnership for collective investments (PSCI) and the Société d’investissement à capital fixe (SICAF). The Swiss Federal Tax Administration has introduced the tax regulations for a taxation of the funds and their investors at the beginning of the year. This article covers first the amended principles of taxation of funds in Switzerland and the existing uncertainties. It focuses on the international aspects like the entitlement of the funds for treaty benefits, the reimbursement by foreign investors of the Swiss withholding tax levied on distributions by the funds and the qualification of foreign funds for Swiss tax purposes.
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Vorhach, Olena. "Personal income taxation in the human capital development incentive." Economy of Industry 4, no. 96 (November 25, 2021): 56–80. http://dx.doi.org/10.15407/econindustry2021.04.056.
Повний текст джерелаАнотація:
The article substantiates the opportunities for stimulating the human capital development through personal income taxation in Ukraine. The need for constant investments in the human capital for improvement of its quality has been substantiated by conceptual provisions of the human capital theory and empiric researches of its influence on economic growth. The completed analysis of theoretical concepts and practical use of income taxes worldwide allows substantiating the fact that concept of a flat income taxation can be successfully used to promote the human capital development. However, the analysis of income tax systems abroad shows that separate taxation tools for personal income, including tax allowances for education, are more efficient. This is especially typical for developing countries. In estimating investments in the human capital in Ukraine, it is found out that the share of working population with high skills increases against the decreasing actual expenses for higher education. In a meantime, foreign countries demonstrate the other economically correct dependence: the qualification level increases as real expenses to gain it increase. The analysis of real national expenses in Ukraine for one student and in the country in general also demonstrate their decrease. This proves the presence of problems in Ukraine that relate to financing the system of higher education. The methods of economic and mathematical simulation by building and parametrizing a number of functions allowed to substantiate the influence of investments in human education on the increase of the highly skilled labor, which in turn leads to the GDP growth. A scientific and methodical approach has been developed, based on the algorithm that takes into account the influence of the highly skilled labor factor (considering expenses for gaining the qualification) on the GDP level. This approach allows estimating the effectiveness of expenses on tax allowances and expediency of their use to promote investments in higher education in Ukraine. The economic consequences of the human capital development incentive by introducing tax allowances in Ukraine have been estimated. It is established that if the state increases expenses for higher education by granting allowances, the share of working population with high skills increases, thereby causing the GDP to grow by means of increasing employment level. However, it has been found out that the expenses for tax allowances are reimbursed only in the case where investments in fixed assets increase and amount no less than 25 % of the GDP.
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Yunina, Fitri. "PENINGKATAN PENERIMAAN PAJAK PENGHASILAN MELALUI PELAKSANAAN EKSTENSIFIKASI PERPAJAKAN PADA KANTOR WILAYAH DIREKTORAT JENDERAL PAJAK ACEH." Akbis: Media Riset Akuntansi dan Bisnis 5, no. 2 (October 28, 2021): 91. http://dx.doi.org/10.35308/akbis.v5i2.3690.
Повний текст джерелаАнотація:
This research purposes to analize and evaluate increasing effectivity of tax income by taxes extensification. Using secondary data by tax income data and number of tax payer that related to taxes extensification during period 2015 to 2019 in Regional Office Direktorat Jenderal Pajak Aceh Result showing that effectivity of tax extensification for increasing taxincome at Kanwil DJP Aceh still low with percentage about 35, 20%. This is because a lot of tax payer that had been registered not yet operate., Pembinaan for new tax payer not optimal, and klasification for business field not proper, example work finder that given non worker at classification business field when they registered, when they not having potention as tax payer. Keywords : Tax extensification and tax effectivity
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Al- Khasawneh, Reem Oqab Hussein. "Role of Electronic Accounting Information Systems in Reducing the Phenomenon of Tax Evasion in Facilities Subject to Income and Sales Tax in the Hashemite Kingdom of Jordan." International Journal of Accounting and Financial Reporting 10, no. 2 (July 2, 2020): 135. http://dx.doi.org/10.5296/ijafr.v10i2.17298.
Повний текст джерелаАнотація:
The study aimed at identifying the role of e-accounting information systems in reducing tax evasion in term of its three stages inputs, processing and outputs. It also explained the role of a compatibility between e-accounting systems and the instructions and procedures of income tax authority for reducing tax evasion. For achieving the purposes of the study, a questionnaire was distributed to employees of tax evasion authority, income and sales tax inspectors. The study found that using e-accounting information systems in the facilities subject to income and sales tax has contributed to a very high degree at input stage whereas the contribution of using e-accounting systems has been high at processing and output stages. In addition, the study indicated that existing the compatibility between e-accounting systems and the instructions of income and sales tax authority has highly contributed to the reduction of tax evasion. It also illustrated that the procedures and methods of professional examination of e-accounting information systems developed by income and sales tax authority have contributed to a very high degree of the reduction of tax evasion. Moreover, the study found that a sufficient experience of employees of income and sales tax authority in the field of using e-accounting information systems has contributed to a very high degree of the reduction of spreading of the phenomenon of tax evasion.
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Thomaz Pignatari, Leonardo. "The Qualification of Technical Services in Brazilian Double Tax Treaties and the Possible Impacts of the Adoption of Article 12B, UN Model Convention." Intertax 49, Issue 8/9 (August 1, 2021): 674–90. http://dx.doi.org/10.54648/taxi2021066.
Повний текст джерелаАнотація:
The qualification of income derived from technical services in Brazilian double tax treaties has always been surrounded by significant controversy between tax authorities and taxpayers. This agitation is exacerbated by the challenges inherent to the taxation of the digital economy and its proposed alternatives. The present study aims to examine the possible impacts of including Article 12B, the recent United Nations (UN) proposal for the taxation of the digital economy, in the qualification of technical services in Brazil. This objective demands a brief historical incursion into the troubled qualification of technical services in Brazil and an overview of the new Article 12B of the UN Model Convention. In addition, the possible impacts of the adoption of such a provision in the Brazilian scenario will be addressed and therefore expose the primary aspects of this new proposal. Ultimately, some conclusions are presented to trace a horizon around the Brazilian service taxation policy in the context of the digital economy. Technical services, taxation at source, United Nations, Article 12-B, digital economy, Brazilian policy.
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Brink, Sophia. "Inkomstebelastinghantering van korting ontvang in die hande van 'n nie-handeldrywende persoon." Journal of Economic and Financial Sciences 7, no. 1 (April 30, 2014): 213–30. http://dx.doi.org/10.4102/jef.v7i1.137.
Повний текст джерелаАнотація:
For income tax purposes, a taxpayer operating a business will account for discount received differently from a taxpayer not operating a business. When a taxpayer operating a business obtains goods or services at a discount, the taxpayer can claim a section 11(a) deduction at the value of the goods or services, net of the discount received. The discount reduces the value of the net reduction of taxable income and the taxpayer is effectively taxed on the discount received. A taxpayer who is not operating a business will not qualify for a section 11(a) deduction (read together with section 23(g)) for goods or services obtained (it does not meet the requirements ‘for the purposes of trade’ and ‘in the production of income’). Discount received in the hands of a non-trading person (often a natural person) is currently not subject to normal South African income tax. The main objective of this article is to investigate whether the existing provisions in the Income Tax Act No. 58 of 1962 and related case law provide a basis for taxing discount received in the hands of the non-trading individual. In order to meet this objective, local literature was analysed to determine the correct income tax treatment and it was found that discount received by a non-trading person meets all the requirements of the ‘gross income’ definition and consequently should be taxable.
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Smith, Michael J. "Ex Ante and Ex Post Discretion over Arm's Length Transfer Prices." Accounting Review 77, no. 1 (January 1, 2002): 161–84. http://dx.doi.org/10.2308/accr.2002.77.1.161.
Повний текст джерелаАнотація:
Treasury Regulations typically require a firm to use its manufacturing cost as one input in calculating the transfer price to be used for tax purposes. Because the characteristics of the firm's capital assets determine the realized manufacturing cost, the firm has an incentive to distort its investment choices in order to receive a more favorable tax transfer price. This represents an ex ante form of shifting income across divisions. Practical difficulties in enforcing the regulations provide the firm with another way to shift income. In particular, regulators often can identify only a range of acceptable transfer prices. As a result, the firm will not use the true “arm's length” transfer price, but will instead choose a transfer price that is more favorable for tax purposes. I find that the opportunity to shift income ex post in this manner may reduce the value of investment-based ex ante income shifting. That is, if the firm has more discretion over the ex post transfer price, then it may invest more efficiently ex ante. Although it is commonly perceived that ex post income shifting is purely deleterious, the analysis shows that it may have benefits.
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Lukman, Elvini, and Purnamawati Helen Widjaja. "THE EQUALIZATION OF PERIODIC VAT RETURN AND ANNUAL TAX RETURN OF CV. LAJ FOR THE YEAR OF 2020." International Journal of Application on Economics and Business 1, no. 2 (August 6, 2023): 543–56. http://dx.doi.org/10.24912/v1i2.543-556.
Повний текст джерелаАнотація:
This research has several purposes, namely to discover the factors that cause difference in the value of gross income reported in Periodic Value Added Tax Return and Annual Tax Return as well as to find out how to perform equalization process to Periodic Value Added Tax Return and Annual Tax Return. This study uses a qualitative descriptive research approach to CV. LAJ, corporate taxpayer who is the subject of this research. With the aim of obtaining data needed in this research, the methods used by the researcher include natural observation, interviews, and documentation studies. The outcomes of the equalization process indicate that the difference in the value of gross income is caused by other operating income transactions, other operating expenses, bonuses, sale discounts, sale returns, claim compensation and cancellation or replacement of output tax invoices.
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Lukman, Elvini, and Purnamawati Helen Widjaja. "THE EQUALIZATION OF PERIODIC VAT RETURN AND ANNUAL TAX RETURN OF CV. LAJ FOR THE YEAR OF 2020." International Journal of Application on Economics and Business 1, no. 2 (August 6, 2023): 543–56. http://dx.doi.org/10.24912/ijaeb.v1i2.543-556.
Повний текст джерелаАнотація:
This research has several purposes, namely to discover the factors that cause difference in the value of gross income reported in Periodic Value Added Tax Return and Annual Tax Return as well as to find out how to perform equalization process to Periodic Value Added Tax Return and Annual Tax Return. This study uses a qualitative descriptive research approach to CV. LAJ, corporate taxpayer who is the subject of this research. With the aim of obtaining data needed in this research, the methods used by the researcher include natural observation, interviews, and documentation studies. The outcomes of the equalization process indicate that the difference in the value of gross income is caused by other operating income transactions, other operating expenses, bonuses, sale discounts, sale returns, claim compensation and cancellation or replacement of output tax invoices.
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Bilquees, Faiz. "Elasticity and Buoyancy of the Tax System in Pakistan." Pakistan Development Review 43, no. 1 (March 1, 2004): 73–93. http://dx.doi.org/10.30541/v43i1pp.73-93.
Повний текст джерелаАнотація:
This paper examines the elasticity and buoyancy of the tax system for the period 1974-75–2003-04. The elasticity of the total tax revenue both with respect to the total GDP and the non-agricultural GDP base is less than unity. Overall, sales tax takes the lead by way of improving revenues. The high coefficient of income tax inclusive of withholding tax, which is an indirect tax, is high. Excluding the withholding tax leads to a lower coefficient. Sales tax with respect to imports and manufacturing also takes care of loss of revenue due to lowering of tariff and excise duties. However, the sales tax coefficient with respect to the GDP base reflects the inclusion of service sector and utilities in the sales tax net, which has serious implications for the poor. The estimates of buoyancy suggest that tax changes did not lead to significant revenue augmentation. The low buoyancy of income tax exclusive of the withholding taxes implies that imposition of massive withholding taxes coupled with an increase in the taxable income limits is working at cross purposes.
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Andresen, Ulf. "Case Law Note: Arm’s Length Net Income for German Withholding Tax and Tax Declaration Purposes." Intertax 48, Issue 8/9 (August 1, 2020): 831–35. http://dx.doi.org/10.54648/taxi2020081.
Повний текст джерелаАнотація:
One hundred years after its creation in 1920, (DE: section 49 (1) no. 6 had originally been created as section 2 no. 2 of the ITA 1920; its content had been moved to the current section 49 in 1934: see M. Stöber, W. Anissimov, I. Heß, G. Hiller, T. Kaligin, J-P. Naujok, section 49, no. 1902 in: Income Tax Act, Commentary, (F. Lademann ed. Publisher, 2020; formerly commented on by Jü. Lüdicke). ) section 49 (1) no. 6 and its 1994 derivative no. 2f Income Tax Act (ITA) are becoming the focal point of a heated discussion, primarily among US headquartered multinationals. The reason for this development is that the Big Four, as their auditors, are forcing their audit clients to build reserves for the potential application of sec. 49 (1) no. 6/no. 2f ITA.( For years after 2005, DE: section 49 (1) no. 2f ITA is the only applicable provision as it reflects the change in scope of DE: section 8 (2) Corporation Tax Act to only assume a business activity by nature of a corporate body if such corporate body was subject to unlimited tax liability in Germany. ) The reason is that this provision may apply to a specific type of cross-border intra-group transaction into which US headquartered multinationals have entered. Transactions in scope are the sale or licensing of intellectual property that a larger number of US multinationals have entered into in the aftermath of the introduction of the BEPS measures to the extent that they have a German nexus.(OECD, Final Reports on Actions 1 through 15, OECD/G20 Base Erosion and Profit Shifting Project, (OECD Publishing, 2015), https://www.oecd.org/tax/beps/beps-actions/ (accessed 28 May 2020). These measures have been translated into national tax provisions, e.g. the German ATAD Transformation Act, Bill as of 24 Mar. 2020, and treaty provisions through the OECD, Multilateral Convention to implement Tax Treaty related Measures to prevent Base Erosion and Profit Shifting (OECD Publishing, 2016) (Multilateral Instrument or MLI), available at, https://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-mea sures-to-prevent-beps.htm (accessed 28 May 2020)). Limited tax liability, withholding tax, Germany transfer pricing, taxation at source sale, transfer of intellectual property (IP), licensing of IP, intellectual property, cost plus method, routine patent/trademark registration services.