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International tax coursework assignment - Essay Example

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The main problem in case of international taxation is the amount of tax that is levied on the residents and the non residents carrying out business operation…
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Download file to see previous pages The international tax system is required to be structured in such a way that any company carrying out its business in more than two countries should be liable to the domestic law of more than one country and the conflict of laws existing between the countries can be resolved by implementing the international law. The company residence acts have been introduced in which the company is considered as the resident of that country where its real business is being carried out. The technical fees services are required to be adopted under which the right to tax is assigned to the respective State of residence.
The fundamental change to the international tax explains that the payment for technical services may erode the source country’s tax base. But the payment of technical services is not often taxed by the source country under the provision of United Nation Model Convention Treaty. Therefore the multinational companies often use this technical fees for availing technical, consulting and management services for generating profit from their subsidiaries. The main aim of the base erosion and price shifting is to provide certainty to the international businesses for harmonizing their international tax rules (Thuronyi, 2003).
The main reason of addition of this provision to the UN model is that more than 100 treaties have been introduced and formulated but there is absence of proper and definite standard of doing the task. Introduction of different treaty creates a problem for the international tax payers who are required to verify the provisions laid by each treaty for carrying out its business operation within the border and abroad. The OECD transfer pricing guidelines has been formulated for the multinational companies and also for the tax administrations. This principle of transfer pricing is accepted by all the companies across the world. OECD approach associated with the intellectual property explains the functions that is outsourced to the ...Download file to see next pagesRead More
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