Significant International Taxation Terms
Advance Pricing Arrangement: An arrangement that determines, in advance of controlled transactions, an appropriate t of criteria for the determination of the transfer pricing for tho transactions over a fixed period of time. An advance pricing arrangement may be unilateral involving one tax administration and a taxpayer or multilateral involving the agreement of two or more tax administrations.
听海歌词Arm’s Length Principle: 阴道炎是什么原因引起的the international standard which states that, where conditions between related enterpris are different from tho between independent enterpris, profits which have accrued by reason of tho conditions may be included in the profits of that enterpri and taxed accordingly.
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Associated Enterpris: Generally speaking, two enterpris are associated where one of them participates directly or indirectly in the management, control or capital of the other or where the same persons participate directly or indirectly in the management, control or capital of both enterpris.
Ba Company: Company situated in a low-tax or non-tax country (i.e. tax haven), which is ud to shelter income and reduce taxes in the taxpayer's home country. Ba companies carry on certain activities on behalf of related companies in high-tax countries (e.g. management rvices) or are ud to channel certain income, such as dividends, interest, royalties and fees.
Tax Avoidance: a term generally ud to describe the arrangement of a taxpayer's affairs that is intended to reduce his tax liability and although the arrangement could be strictly legal, it is usually in contradiction with the intent of the law it purports to follow.
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Beneficial Owner: A person who enjoys the real benefits of ownership, even though the title to the property is in another name. it is often important in tax treaties, as a resident of a tax treaty partner may be denied the benefits of certain reduced withholding tax rates if the beneficial owner of the benefits is resident of a third country.
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Best Method Rule: Transfer pricing rule requiring that a taxpayer u the transfer pricing method that results in the most reliable measure of an arm's length price. This rule doesn'二战的影响
t prescribe priorities between various methods.
Captive Insurance Company: wholly owned subsidiary of a multinational group of companies which exclusively insures or reinsures the risks of companies that belong to the group. A captive insurance company is usually established in a low-tax country. Whether premiums paid to captive insurance companies are recognized as business expens depends on the country in question.
h股etfCentral Management and Control: where the central management and control is located is a test for establishing the place of residence of a company. Broadly speaking, it refers to the highest level of control of the business of a company.
Comparability Analysis: Comparison of controlled transaction conditions with uncontrolled transaction conditions. Controlled and uncontrolled transactions are comparable if none of the differences between the transactions could materially affect the factor being examined in the methodology, or if reasonably accurate adjustments can be made to eliminate the material effects of any such differences.
Comparable Uncontrolled Price: A transfer pricing method that compares the price for property or rvices transferred in a controlled transaction to the price charged for property or rvices transferred in a comparable uncontrolled transaction in comparable circumstances.
Conduit Company: company t up in connection with a tax avoidance scheme, whereby income is paid by a company to the conduit company and then redistributed by that company to its shareholders as dividends, interest, royalties, etc.
Contract Manufacturer: A manufacturer, in most cas, located in a low-cost jurisdiction, which has a licen to u an intangible property developed by its parent company. The manufacturer us the intangible property to produce tangible property which is then resold to the parent for distribution to ultimate customers.
Contribution Analysis: where the profit-split method is applied in transfer pricing cas, a contribution analysis requires that the combined profit be divided between associated enterpris bad upon the relative value of the functions performed by each of the asso
ciated enterpris participating in the controlled transaction.
Controlled Foreign Companies: Companies usually located in low tax jurisdictions that are controlled by a resident shareholder. CFC legislation is usually designed to combat the sheltering of profits in companies resident in low-or no-tax jurisdictions. An esntial 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. Generally, only certain types of income fall within the scope of CFC legislation, i.e. passive income such as dividends, interest and royalties.
