2. MEANING
It refers to tax levied on the cross border transaction.
Transaction may take place between two or more persons or entity in two or more
countries or tax jurisdiction.
Such transactions may involve a person in one country with property and income
flows in another.
3. BASES OF INTERNATIONAL TAX SYSTEM
It is expected that the international tax system should be neutral that means it
should not affect economic efficiency.
A firm should not be taxed twice for the same income so these three concepts
came up:-
Tax Neutrality
Tax Equity
Avoidance of Double taxation
4. TYPES OF TAXES
Income tax
With-holding tax
Value- added tax
6. INTERNATIONAL TAX MANAGEMENT STRATEGY
Firms need to decide whether the profits should be with subsidiaries or to
repatriate within the home unit
If it stays with the subsidiaries, the profit would be reinvested in profitable
channels
Following above would hamper the purpose of investment in subsidiary
Tax burden would be reduced if the firm allocates more cost in high tax
country and shows greater profits in low tax countries
Transfer pricing in a possible and limited way could reduce the above
OECD does country by country reporting under its action plan
7. TAX HAVENS COUNTRIES
A tax haven country is one that that has zero rate or a very low rate of
income tax and with holding tax.
8.
9. Classification in groups
GROUP 1 GROUP 2 GROUP 3 GROUP 4
Bahamas British Virgin
islands
Costa Rica The Netherlands
Bermuda The Netherlands
Antilles
Hong Kong Luxembourg
The Cayman
Islands
Montserrat Panama Switzerland
Nauru Gersey Liberia Liechtenstein
New Hebrides The Isle of Man Gibraltr
Turks Guernsey Barbados
Caicos Islands Grenada
10. Bermuda – Personal Income Tax Rate 0% – GDP per capita of $91,479.
Qatar – Personal Income Tax Rate 0% – GDP per capita of $60,796.
The Cayman Islands – Personal Income Tax Rate 0% – GDP per capita of $54,827.
Kuwait – Personal Income Tax Rate 0% – GDP per capita of $30,147.
United Arab Emirates – Personal Income Tax Rate 0% – GDP per capita
of $25,773.
Brunei – Personal Income Tax Rate 0% – GDP per capita of $25,140.
Bahamas – Personal Income Tax Rate 0% – GDP per capita of $20,690.
Bahrain – Personal Income Tax Rate 0% – GDP per capita of $18,128.
Saudi Arabia – Personal Income Tax Rate 0% – GDP per capita of $17,820.
Oman – Personal Income Tax Rate 0% – GDP per capita of $12,472.
11. DOUBLE TAXATION
Domestic double taxation arises when comparable taxes are
imposed within a federal state by sovereign tax jurisdictions
of equal rank. International double taxation arises when
comparable taxes are imposed in two or more states on the
same taxpayer in respect of the same taxable income or
capital, e.g. where income is taxable in the source country and
in the country of residence of the recipient of such income.
12. DOUBLE TAX AVOIDANCE AGREEMENT IN
INDIA
Mentioned under Section 90 of the Income Tax Act
The act gives empowerment on avoidance of double taxation by signing an
agreement with foreign government
Presently 4 dozen treaties are signed
Treaties are either comprehensive or partial
If no treaty exists, the Indian resident will get a tax relief under Section 91 of
IT act