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Taxes

Force of attraction

One must understand the importance of a permanent establishment when it comes to taxation. This refers to the concept where a country taxes the income and property of a business located within its borders. However, it also extends to all income earned by the foreign head office from sources within the country and all property owned by the foreign head office situated in the country. Interestingly, the OECD model treaty does not allow the application of this concept.

Stock exchange turnover tax

A common term in finance is "securities transaction tax", which refers to the tax imposed on the buying and selling of securities on the stock exchange. This tax is usually ...

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Final tax

Tax treaties play a crucial role in international taxation by limiting the withholding tax imposed by the country of source. This means that the rate applied in a treaty cou...

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Bank secrecy provisions

Bank secrecy laws are regulations that mandate financial institutions to keep customer information confidential from external parties, such as tax authorities. These provisi...

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Quarantining

The foreign tax credit system involves the calculation of foreign tax payable on specific categories of foreign income, which can then be applied as a credit towards domesti...

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