The tax treatment of foreign active business incomepreventsinternational double taxation
The lump - sum foreign tax creditpreventsinternational double taxation
foreignsource income earned by a resident of a country ... relief provisionsto preventdouble taxation International double taxation
positions ... their national tax lawscould leadto international double taxation
Extension of the flat - rate tax credits on foreign companies ’ permanent establishmentsTo preventinternational double taxation
an agreement between two countriesto preventinternational double taxation
The key topic ... which was foundto createeconomic international double taxation
U.S. tax at the marginal tax rate applicable to Afterall 's businessresultingin international double taxation
U.S. tax at the marginal tax rate applicable to her businessresultingin international double taxation
With these criteria , the OECD seeksto preventinternational double taxation from occurring
tax authorities ... a uniform mannerwill preventinternational double taxation
a tax adjustmentleadsto international double taxation
Law and Political Science ; Abstract : For preventing economic double taxation and neutralization of choice between direct and indirect investments , states might grant domestic funds certain tax advantages while not extending it to non - residentsresultin international double taxation
abilityto leadto international double taxation
The double taxation treaty also aimsto preventinternational double taxation
3 elements of taxationmay causeinternational double taxation
Member States(passive) caused byinternational double taxation
from this requirement.[8resultsfrom this requirement.[8
from this requirement.[7resultsfrom this requirement.[7
from this requirement.[4resultsfrom this requirement.[4
from differences in entity characterizationresultingfrom differences in entity characterization
where two jurisdictions seek to tax the same transactions or activitiesmay resultwhere two jurisdictions seek to tax the same transactions or activities
when income arises in one countrywould ... resultwhen income arises in one country
from the conflict of taxation powers used on the same incomeresultingfrom the conflict of taxation powers used on the same income
distortions(passive) caused bydistortions
from applicationresultingfrom application
from residenceresidence conflicts through tax treaties Many residence residence conflicts involving legal entitiesresultingfrom residenceresidence conflicts through tax treaties Many residence residence conflicts involving legal entities
the domestic participation exemption regimetriggeringthe domestic participation exemption regime