Chapter

Principles of International Taxation

January 2014

January 2014

DOI:10.1057/9781137443809_6

In book: Migration States and Welfare States (pp.32-35)

Authors:

Assaf Razin

Tel Aviv University

Efraim Sadka

Tel Aviv University

Each country must decide (i) whether, and if so at what rate, to tax its citizens/ residents on their foreign-source income (e.g. wages, interests, dividends, etc.); and (ii) whether, and if so at what rate, to tax foreigners on their income originating from sources within the jurisdiction. This chapter describes the main principles of international taxation.

ResearchGate has not been able to resolve any citations for this publication.

ResearchGate has not been able to resolve any references for this publication.

Article

Double income taxation as a response to tax competition in the EU

September 2001 · Intereconomics

The following article discusses the undesired consequences of tax competition and presents a proposal for tax reform derived from a very general normative basis: the idea of exchange between governments and taxpayers and the principle of equality. The aim is to tie tax competition to jurisdictional competition in general and thereby maintain tax competition as a productive procedure instead of ... [Show full abstract] abolishing it by harmonising tax systems. Surprisingly, systematic double taxation of income, as factor income following the source principle and as citizens' income following the residence principle, is one element of the solution. The other is unitary taxation of business income.

Chapter

International Taxation

January 2002

Imad Moosa

International taxation involves the imposition and levying of taxes on cross-border transactions. This action invariably gives rise to problems, since it involves more than one tax system with inherent differences. Countries differ, inter alia, with respect to the types of taxes they impose, the tax rates, the tax base to which the tax rates are applied, and whether or not tax is levied on income ... [Show full abstract] generated by their citizens if these citizens reside outside their national boundaries. Individual country practices with respect to taxation have evolved over a very long period of time.1

Chapter

Tax Systems of Economies in Transition

January 1998

Originally, all tax systems of the formerly socialist countries very much resembled the tax system of the Soviet Union with its emphasis on taxing companies combined with a complicated system of turnover taxation where rates were often implicitly determined through administered pricing. Income taxes—in particular the wage tax—played an insignificant role in this context, but there was a payroll ... [Show full abstract] tax on wages that went largely unnoticed by taxpayers and had virtually no effect on labour supply or demand.1

Article

Foreign Sourced Income - The Received Basis of Income Taxation

February 2007

Liu Hern Kuan

Unlike many countries, Singapore residents are taxed on a territorial (as opposed to a world-wide or global) basis. Income is taxed when it accrues in, or is derived from or is received in Singapore. There is much uncertainty over how income will be received for tax purposes. This article explores the received basis of income taxation.

Article

Doppelte Anrechnung fiktiver ausländischer Steuern bei doppelt ansässigen ausländischen Kapitalgesel...

March 2011 · SSRN Electronic Journal

Thomas Kollruss

Neue Erkenntnisse im Bereich der (internationalen) betriebswirtschaftlichen Steuerlehre bezüglich der Besteuerung doppelt ansässiger (ausländischer) Kapitalgesellschaften: a) Bei einer im DBA-Ausland doppelt ansässigen ausländischen Kapitalgesellschaft ist eine doppelte Anrechnung fiktiver ausländischer Steuern nach DBA auf Dividenden einer solchen Gesellschaft auf der Ebene des deutschen ... [Show full abstract] Gesellschafters möglich; b) Systematik und Mechanismus der per-country-limitation (§ 68a EStDV) im Zusammenhang mit nur einem Einkünftebezug (Dividende) mit doppelter ausländischer Quelle erörtert anhand von Dividenden einer doppelt ansässigen ausländischen Kapitalgesellschaft. This paper firstly reveal that a double tax matching credit by tax treaties can be claimed regarding the taxation of dividends at the shareholder level distributed by a dual resident company/corporation.

Article

Special rules against tax avoidance: Taiwan’s experience

September 2023 · Vestnik of Saint Petersburg University Law

Roman A. Shepenko

States and the territories implementation their tax rights in relation to the objects of taxation by concepts of taxation is determined. Tax conceptions to be applied primarily in relation to direct taxes are territorial and global. The territorial conception assumes that taxes are levied on the object of taxation originated or received in the state (territory). This conception is addressed to ... [Show full abstract] residents and non-residents. The global conception assumes that taxes are levied on the object of taxation regardless of the place of its origin. This conception is addressed to residents. Ideally, states and territories should limit their tax rights to income from national sources. Accordingly, the principle of non-double taxation will not be violated and there is no need for special rules. Initially, states and territories followed the territorial concept, but over time approaches have changed. As a result, the problem of tax avoidance has become the focus of attention. Their unilateral application does not give the desired result, and therefore international treaties are concluded or amended. Special rules against tax avoidance are on the agenda of the authorities of various states, including unrecognized ones. There is a certain specificity in the regulation in relation to unrecognized states and territories with a special status. Some of these entities are even members of international organizations, but do not have an extensive network of treaties containing tax provisions. In the given article, an attempt to systematize special rules against tax avoidance in Taiwan is made.

Article

Full-text available

Source and Residence: New Configuration of Their Principles

Until the early 1990s New Zealand policy was to tax residents on their worldwide income and non-residents on income derived from New Zealand. The policy changed slightly in the 1990s when it became clear that taxing non-residents on income derived in New Zealand was a disincentive to foreign investment. Thus, since the early 1990s the focus of successive New Zealand governments has moved towards ... [Show full abstract] residence taxation and away from source taxation. However, with the intention of maintaining a strong tax base New Zealand has continued to tax a good deal of income derived in New Zealand by non-residents in a variety of ways.

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Article

Full-text available

Convergence in Growth Rates: The Role of Capital Mobility and International Taxation

September 1994

We consider the role of capital mobility and international taxation. In explaining the observed diversity in long-term growth rates. Our major finding is that, under capital mobility, international differences in taxes will not matter for total growth differentials. Policy differences have a role to play in per capita growth differentials, however, when they lead to a divergence in the after-tax ... [Show full abstract] rates of return on capital across countries, as when the residence principle is adopted universally. When this is the case, how tax differences affect the growth rates of population and human capital will depend on the relative preference of the individual household towards these two engines of growth. Optimal tax policies are found to be growth-equalizing with and without policy coordination.

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Article

New Zealand Trust Taxation: The International Dimension

John Prebble

International aspects of New Zealand’s trust regime are driven by three things. First, operating independently of the trust regime is New Zealand’s policy to tax all income that has a New Zealand source. Secondly, there is the structural factor of the trust regime that trusts themselves are not taxpaying entities. Thirdly, New Zealand has adopted as policy the principle that the mere residence of ... [Show full abstract] a trustee should not determine tax liability. The effect of the policy to tax all income from New Zealand is that any income derived by any trustee is taxable if the income has its source in New Zealand. Trustees are taxed as the economic agents of the settlor. Foreign-source beneficiary income is taxable if the beneficiary resides in New Zealand, but not taxable if the beneficiary is non-resident, even if the trustee is resident. Whether trustee income (that is, income accumulated within trusts) is taxable depends on the residence of the settlor. If the settlor is non-resident, then, ordinarily, the income is not taxable, even if the trustee is resident. If the settlor is resident, then the income is taxable, even if the trustee is non-resident.

Article

911 v. 913: HOW THE FLAWS OF THE FOREIGN EARNED INCOME EXCLUSION COULD BE CORRECTED BY A MODIFIED VE...

Ryan M Borgmann

This Article addresses the use of earned income as basis for allowing a tax benefit to individuals who live and work abroad. With the exception of a short period of time in the late 1970’s and early 1980’s, earned income has been used to provide a tax benefit for United States citizens and residents living and working abroad. The reasoning for this tax benefit has always been to provide ... [Show full abstract] assistance for the higher cost of living and higher tax rate of living in a foreign country, yet the tax benefit has been available to every individual living abroad, independent of whether they are need of tax assistance due to higher expenses. This Article provides an analysis of the history of the foreign earned income exclusion and the flaws with using an individual’s income as the basis to provide a tax benefit. After identifying the problems with the use of earned income, the Article provides a solution that utilizes Section 913 as its foundation; the Tax Code Section that was in place in the aforementioned late 1970’s and early 1980’s. The Article concludes that using a modified version of Section 913 would provide the tax benefit to those individuals to whom the foreign earned income exclusion was designed to assist, while solving some of the concerns posed when Section 913 was repealed in 1981.

Chapter

Taxation of Corporate Income

February 2024

Peter Harris

This chapter projects Chapters 1 and 2 into an international setting by considering how the corporate tax system behaves when international factors are introduced. It continues to presume the capital structure of the corporation does not change. The focus is on the differing jurisdictions to tax resident versus non-resident corporations, and the chapter is structured around this distinction. ... [Show full abstract] Three cross-border options where there is a jurisdiction to tax are identified for each of resident and non-resident corporations. The relationships between these options are considered with a particular emphasis on how the tax outcome differs from a purely domestic setting. With respect to resident corporations, it is noted that corporate-level dividend relief does not work well when foreign income is derived, but shareholder-level systems do. By contrast, shareholder-level dividend relief systems do not work well in the context of outbound dividends, but corporate-level dividend relief systems can (but are restricted by recent international norms). Corporate-level dividend relief does not work at all with respect to non-resident corporations. Here many countries’ corporate tax systems distort the choice of whether a non-resident should create a presence through a branch or subsidiary.

Article

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The principle of proporTionaliTy applied in sTaTe Tax- es and income Tax

January 2022 · Revista del Posgrado en Derecho de la UNAM

Revista del posgrado en derecho de la UNAM | revistaderecho.posgrado.unam.mx año 9, Nº 15, julio-diciembre 2021 | https://doi.org/ El principio de proporcionalidad aplicado en los impuestos estatales y el impuesto sobre la renta 1 Resumen: El objetivo de este trabajo es estudiar el principio de proporcionalidad aplicado en las tasas contributivas Estatales para medir la progresividad de los ... [Show full abstract] impuestos establecidos en las entidades federativas, y la tarifa tributaria del Impuesto So-bre la Renta (ISR). Se realizó un análisis hermenéutico-crítico para construir una base de datos de los tipos de impuestos y sus tasas, y se aplicó el índice de Suits para calcular la progresivi-dad tributaria. El estudio concluye que el sistema de tributario es regresivo pero cercano a lo proporcional. La aportación del estudio reside mostrar el grado de progresividad de las tasas tributarias Estatales y la regresividad del sistema tributario. El trabajo es de interés para legisladores, entidades públicas de recaudación, analistas en finanzas públicas, fiscalistas, econo-mistas, y público en general.

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Principles of International Taxation

Abstract

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