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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.

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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Benefit test

When assessing the deductibility of payments made to a related company in a multinational group for intra-group services, tax authorities require evidence of a tangible bene...

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Terrtoriality principle

One commonly used term in the world of finance is "territorial taxation". This concept refers to the practice of taxing individuals or businesses only within the boundaries ...

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Rollover relief

Roll-over relief is a valuable tool in the world of finance, providing a means to defer the burden of capital gains tax. This relief allows for the postponement of a taxable...

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