Tax Treaties and International Taxation - Research Paper Example

 Atlantica and Freedonia: Tax Treaty Model In choosing a tax treaty model, Atlantica and Freedonia will be guided by the objective of preventing tax evasion and double taxation as well as the manner in which the tax treat model achieves these ends. Bilateral tax treaties typically have two general purposes; the prevention of double taxation and the prevention of tax evasion.1There are a variety of tax treaty models that can be used by Atlantica and Freedonia for the purpose of accommodating their respective and mutual tax issues. The two main tax treaties published by international bodies are the OECD’s Model Convention with Respect to Taxes on Income and Capital (OECD Model) and the UN Model Double Taxation Convention between Developed and Developing Countries (UN Model). Model tax treaties in general do not require that contracting countries coordinate their tax rates. However they typically require that designated exemptions and credits are applied to earnings that are repatriated.2 Regardless of what model Freedonia and Atlantica choose to draft, a tax treaty model there is going to be interpretation and application considerations. This is because tax treaties are international in character and are derived from customary international law. However, what distinguishes tax treaties from customary international laws is that they have the capacity to alter national revenue laws in terms of application.3 The language in tax treaty models is necessarily vague because they are calculated to be used in revenue systems that are different from one another. The result is, the way that a treaty binding two countries is interpreted can be quite different.4 Both the OECD Model and the UN Model provide commentary to assist in the interpretation of their respective provisions.5 The commentary to the OECD Model makes references to domestic provisions regulating anti-avoidance measures, while the UN Model does not.6 In this regard, the OECD is preferable to the UN Model for the purpose of resolving interpretive difficulties that might arise in the event national tax laws conflict with tax treaty obligations. a. The OECD Tax Model i. Interpretation under the OECD Tax Model The definition of residence of a taxpayer can expose the taxpayer to double taxation, depending on whether or not domestic laws can be reconciled to eliminate one residence in favour of another. For instance, the national laws of more than one country might determine that a particular taxpayer is resident in their respective jurisdictions and therefore liable to tax assessment on the same income in each of these countries. Article IV (3) of the OECD Model as revised in 2008 is also known as the treaty tie-breaker rules. In this regard, where a taxpayer is exposed to dual residence, the OECD Tax Model Treaty Article IV(3) mandates that the taxpayer’s “place of effective management” will determine residence.7 However, in order for this particular provision to benefit Freedonia and Atlantica, both countries will be required to come to some agreement on how to interpret the phrase “effective management”. Van den Berg and van der Gulik explain that although the OECD’s commentary on Article IV(3) provides interpretive guidelines, it is still possible for the phrase to be interpreted differently.8 At a joint seminar conducted by the International Fiscal Organization and the OECD it was acknowledged that interpreting the place of effective management could give rise to two possible interpretations. One possible interpretation is that the place of effective management could be the place where the directors typically meet. Another possible interpretation deems the place of effective management to be the place where senior management runs the business.9 In order to reconcile the potential for inconsistent interpretations of the place of effective management, paragraph 24.1 in the commentary to Article IV(3) provides as follows: …the competent authorities of the Contracting States shall endeavour to determine by mutual agreement the Contracting State of which such person shall be deemed to be resident for the purposes of the Convention, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors.10 It therefore follows that in order to avoid confusion over dual residency and the dual taxation possibilities that might arise out of it, Atlantica and Freedonia should therefore agree to a working definition of effective management by incorporating the alternative OECD Article IV(3) into their bilateral Tax Treaty. ii. Reducing, Eliminating and Sharing Taxes under the OECD Tax Treaty Model Obviously the treaty tie-breaker is significant for reducing the risk of double taxation, one of the primary purposes of tax treaties. Other provisions for reducing the risk of double taxation within the OECD’s Model Tax Treaty are included in various Articles ranging from Articles 5 to 24. Cumulatively these Articles make provision for the classifying and assigning tax liabilities so as to avoid the possibility of dual taxation.11 This is accomplished by the OECD Model Tax Treaty by classifying income type and source and assigning taxing entitlements among the Contracting States.12 There are three basic ways that taxing entitlements are divided under the OECD. They are: 1. A Contracting State may be entitled to full taxing; 2. Contracting States may be entitle to limited or shared taxing rights; or 3. One Contracting State may not be entitled to any taxing rights.13 Article I of the OECD Model provides that the treaty when adopted will apply to persons who are resident in “one or both of the Contracting States.”14 For the purposes of the OECD Model Tax Treaty, a person is defined in Article III(1) as “an individual, a company and any other body of persons.”15 The term “resident” is defined by Article IV (2) as “domicile, residence, place of management or any other criteria of a similar nature.”16 As explained previously, the tie-breaker clause is used to confine residence for the purpose of taxation to one jurisdiction. Article II provides the applicable taxes and these include taxes on income and capital imposed by a Contracting State.17 Article VI applies to taxes applicable to income from immovable property and provides for the right to tax income on immovable property earned by a resident of a Contracting State situated in the territory of another Contracting State.18 In other words, a resident in one Contracting State with realty in another Contracting State will be required to pay taxes on income from the property situated in the Contracting State where the property is located despite the fact that he is resident in the other Contracting State. The result is, the State where the source of income is derived or the “situs” where the assets are located will have primary taxing authority under Article VI of the OECD Tax Treaty Model.19 Business profits are regulated by Articles V and VII of the OECD Tax Treaty Model. By virtue of Article VII (1), profits derived from enterprises which are conducted by a resident of a Contracting State shall only be liable to taxes in the State where the enterprise is resident20. However, if the enterprise conducts business in the other Contracting State where he or she have a permanent establishment, taxes are assessable it that other State. In that case, the taxes will only be applicable in the other Contracting State on the income arising out of the “permanent establishment.”21 In this regard Article V defines a permanent establishment as “a fixed place of business through which the business is wholly or partly carried on”.22 The permanent establishment can include a “management, branch, an office and a factory” but does not cover “some activities” conducted by a “foreign enterprise if they continue for a period of less than certain months, say half year.”23 Article X(1) of the OECD Model Tax Treaty provides for taxation of dividends in the State where the shareholder is resident.24 The OECD Model Tax Treaty provides for the application of a maximum tax rate to reduce the risk of double taxation on dividends that can be derived in one contracting state and applied in another contracting state. Article XI(1) confers upon the resident state unfettered authority to tax recipients. Even so, the other contracting state representing the source state is at liberty to tax the interest, but only by the application of a maximum rate at 10% of the gross profits.25 Article 12 however, unlike Articles 10 and 11 of the OECD Tax Treaty does not make allowances for tax sharing. In the event of royalties, the resident State enjoys exclusive taxing authority over the investor.26 Amatucci et al explains: The reasoning that lies behind this policy choice is to enable the residence State to recapture the revenue forgone by allowing deductions for the expenses incurred by resident taxpayers for the development of the right in respect of which royalties are being paid.27 Similarly, Article XV confers upon the Contracting State the exclusive right to collect taxes on salaries and other means of remuneration from the resident of the Contracting State.28 However, if the employment is conducted in the other Contracting State, that other State is also entitled to collect taxes on the remuneration or wages arising out of that part of the employment conducted in its territory and only in the following circumstances: 1. The employee’s stay in the State where some employment activity takes place is longer than 183 days over the course of one year. 2. The remuneration is discharged “by or on behalf of an employer who is resident in the State of activity.”29 3. The wages or remuneration is covered by a permanent establishment “that the employer has in the State of activity.”30 The methods for reducing, eliminating, and sharing taxes between Contracting States are exhaustive, but generally follow the methods described above. The general idea is ensure that taxing authorities are not denied applicable taxes and that taxpayers are not unduly burdened by the potential to pay double taxes on the same income. iii. Treaty Shopping The risk of treaty shopping has been the subject of concern for tax authorities. Tax treaty shopping occurs when residents of countries not party to the bilateral tax treaty attempt to benefit from the tax benefits contained in the tax treaty. This is accomplished by virtue of a process known as tax treaty shopping and involves setting up a business in one of the treaty countries or “engaging in income-stripping transactions with a treaty-country resident.”31 Amatucci et al describes tax treaty shopping as: …the routing of income arising in one country to a person in another country through an intermediary country to obtain the tax advantage or tax treaties.32 Although the commentaries to Article 1 of the OECD Tax Treaty Model expresses concerns about the potential for tax treaty shopping, the OECD only provides limited safeguards against the incidents of tax treaty abuse. In general anti-tax treaty shopping provisions are designed to limit the application of tax benefits under the treaty.33 The OECD takes a rudimentary approach to treaty shopping and Article IV(1) provides that the treaty shopper is required to be a resident in that he must be fully liable for tax assessment on international income under the tax legislation of the domestic laws.34 Similarly, Article X which apply to taxation on dividend, Article XI which applies to taxation on interest and Article XII which applies to taxation on royalties each provide that only beneficial owners can obtain benefits under the treaty.35 Essentially, the OECD Tax Treaty Model makes provision for excluding the “concessional withholding” of “tax benefit from the legal owner” if he does not qualify as “the beneficial owner and the beneficial owner is not resident in the same Contracting State.”36 Essentially, the legal owner will not be in a position under the terms of the OECD Tax Treaty Model to benefit if he is by definition no more than a figure head in the business with little powers such as those found in nominee shareholders or conduit corporations unless the beneficial owner is simultaneously resident in the relevant State.37 iv. Tax Sparing The issue of tax sparing is particularly important to Freedonia and Atlantica’s bilateral tax treaty since Freedonia, as a developing country grants corporate tax holidays to foreign-owned subsidiaries established in Freedonia for the first four years. Tax sparing is a tool used to improve the economic advancement developing countries and typically involves tax sparing credits as opposed to the usual credit.38 Typically the Contracting State offering tax sparing credits confers upon the other state a specific credit regardless of the fact that the foreign “withholding tax actually paid is lower.”39 The OECD reports that the tax sparing is vulnerable to abuse by taxpayers and as a result can result in losses in terms of revenue for both parties to the bilateral treaty.40 In its early days the OECD did not specifically address tax sparing, however in its 2000 revision of the Tax Treaty Model, its commentary advised about the potential of tax sparing abuse and advised that tax sparing only be utilized in instances where the economic potential of the Contracting State to which the tax sparing is applied “is significantly” lower than “that of the OECD country.”41 On the facts however, the Contracting State offering the tax sparing incentive is a developing country and not an OECD country. Moreover, there is nothing on the facts indicating the economic status of Atlantica and whether or not it is a developing country or a developed country. Assuming that the Atlantica is an OECD country with lower economic potential than Freedonia, the two countries may consider the recommendations provided for by the OECD in its adaptation of its report Best Practices in Designing Tax Sparing Provisions. In the report the OECD recommends that tax sparing provisions should be specifically defined, specify eligible incentives, ensure that tax sparing is conferred only for previously agreed and defined concessions, should provide a sunset clause and tax holiday should be narrowly based.42 Since the sunset clause is for four years and appears to be for the purpose of attracting foreign investors, these incentives and limitations should be clearly defined in the bilateral treaty between Atlantica and Freedonia should they adopt the OECD Tax Treaty Model. v. Information Sharing One of the primary purposes of the bilateral tax treaty is for facilitating the exchange of information, a particularly necessary tool for tax administration. Article XXVI of the OECD Tax Treaty Model requires taxing authorities in Contracting States to exchange information that “foreseeably relevant for carrying out the provisions” of the Convention and for administering and enforcing the domestic tax laws of the Contracting States.43 Any information collected pursuant to Article XXVI(1) shall be treated as confidential under the laws of the relevant Contracting State and will only be disclosed to the relevant authorities.44 Moreover, the information collected will only be used for the purposes for which it is collected.45 Article XXVI(3) of the OECD Model also protects the Contracting States from onerous duties by providing that nothing in the Convention will be interpreted as imposing upon the Contracting State a duty to conduct any administrative business that would contradict the laws and/or practices of either of the Contracting States.46 Neither shall the Contracting States be obliged to impart information that cannot be obtained under the laws of either of the Contracting States.47 By virtue of Article XXVI(3) neither Contracting State can be compelled to provide information that is calculated to “disclose any trade, business, industrial, commercial or professional secret or trade process” or any information that “would be contrary to public order.”48 Article XXVI(4) is designed to accommodate cooperative information exchanges and provides that when information is requested of one Contracting State by the other Contracting State, the other Contracting State is required to use its own information collection system to provide the requested information even if the other State may not require that information “for its own tax purposes.”49 Although Article XXVI(4) is subject to the provisions contained in Article XXVI(3) described in the previous paragraph, it cannot be used to refuse to provide information on the grounds that the information is not relevant to tax queries in domestic situations.50 Similarly, Article XXVI(5) provides that it will not be permissible to refuse a Contracting State’s request for information on the grounds that the information is in the custody of a: bank, other financial institution, nominee or person acting in an agency or fiduciary capacity or because it relates to ownership interests in a person.51 Clearly Article 26 of the OECD Model is coached in terms that provide for the free exchange of information between Contracting States but at the same time provides safeguards against going on fishing expeditions by providing for the free exchange of relevant information. b. The UN Tax Treaty Model Article 3 of the UN Tax Treaty Model defines person as “an individual, a company and any other body of persons.”52 For the purposes of determining taxpayers and eligibility for tax assessments, exemptions and liabilities, the UN Tax Treaty Model provides definitions of permanent establishment and residence in much the same manner as the OECD Tax Treaty Model. Although the UN Tax Treaty Model goes into greater detail with its definition, its ultimate definition is substantively the same as that provided for in the OECD Model. In this regard, for the purposes of defining which taxpayers will be entitled to exemptions, limitations or concessions under the tax treaty between Freedonia and Atlantica both the OECD Model and the UN Model provide essentially the same definitions. Likewise, Article 6 of the UN Model applies to the income from immovable property in much the same manner as the OECD Tax Treaty Model, providing for income derived from immovable property in one state to be taxed in the other Contracting State.53 The presumption is that the income is taxable in the event the interest or income from immovable property is sourced or paid in a Contracting State. Ultimately, the UN Model makes provision for the sharing and limitation of taxes between Contracting States to a bilateral tax treaty in an effort to avoid double taxation. As for anti-tax treaty abuse measures, the UN Model basically relies in great part on the Commentaries made by OECD Tax Model prior to 2003. Similar observations are made throughout the UN Model’s Commentaries on tax credits and anti-sparing provisions. A similar trend follows with respect to information exchange. In this regard, there are no discernible differences between the methods employed by the UN Model and the OECD Model for preventing double taxation, treaty abuse and tax avoidance. Freedonia and Atlantica: Transfer Pricing Legislation Transfer pricing is the price that a business transfers assets, goods, or services within the same entity such as a subsidiary or a parent.54 The practice of transfer pricing can compromise government objectives to collect taxable revenues in cases where business entities maintain branches across borders. The problem arises when multinational corporations use transfer pricing techniques to minimize tax liabilities globally. In seeking to overcome the possibility that multinational corporations might use their respective jurisdictions to minimize tax liabilities or use other jurisdictions to minimize their tax liabilities at home, Freedonia and Atlantica might wish to look to the UK and other tax jurisdictions for guidance in drafting their own transfer pricing and controlled foreign company legislation. The UK, the US and a number of other OECD Member States typically mirror the OECD’s guidelines for the implementation of local transfer pricing laws in bilateral treaties.55 Many OECD countries also adopt the OECD’s arms length principle as enunciated in the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. 56 Freedonia and Atlantica should likewise take this approach and look to the OECD’s Transfer Pricing Guidelines for transfer pricing legislative guidance. In this regard, the OECD describes the arms length principle mandates that the transfer price should: …be the same as if the two companies were indeed two independents, not part of the same corporate structure.57 In general the OECD Transfer Pricing Guidelines are predicated on three specific goals. They are: Reducing non-compliance opportunities. Providing assistance with compliance. Incentives against non-compliance.58 The UK maintains a comprehensive transfer pricing legislative framework. The main transfer pricing rules are set out in three different pieces of legislation. They are the Tax Act 1988 Section 770A which implements the Tax Act 1988 Schedule 28AA, the Finance Act 1998 Sections 109 to 11 and the Advance Pricing Agreements in the Finance Bill 1999 Clauses 76 and 77. The UK’s Inland Revenue also provides detailed explanation for the requirements for record-keeping, penalties and cross-border funding. These explanations are found in the Inland Revenue’s Tax Bulletin Issue 37 of 1998 and Issue 38 of 1999. The most important legislative requirement is that all taxpayers are now bound by the arm’s length principle.59 Cumulatively, the UK’s transfer pricing legislation is designed to give effect to Article 9(1) of the OECD’s Model Tax Convention 2003 which reads as follows: Where: (a) an enterprise of a contracting state participates directly or indirectly in the management, control or capital of an enterprise of the other contracting state; or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise in a contracting state and an enterprise of another contracting state; and in either case, conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.60 The UK’s legislation also requires that for the purposes of applying the arms length principles, the applicable rules are those that are provided for in the OECD Transfer Pricing Guidelines. The OECD Transfer Pricing Guidelines, 2001 provide for examination practices and policies, the burden of proof and penalties.61 The OECD Transfer Pricing Guidelines advises tax administrators to proceed in a flexible manner and not to insist upon transfer pricing precision.62 Tax administrators are also asked not to dismiss the taxpayer’s commercial judgment so that the arms length principle analyses is linked to “business realities.”63 The OECD Transfer Pricing Guidelines does not suggest who should bear the burden for proving an inaccurate profits assessment and allocation of assets for tax purposes. However it provides for the approach to be taken by tax administrators in the event of either scenario. In jurisdictions where the taxpayer bears the burden of proving that profit assessments and allocations are accurate, and where the taxpayer is found not be acting in good faith, tax administrators may estimate the taxes on income and profits.64 A taxpayer is not acting in good faith when he/she fails to cooperate with a tax administrator’s request for supporting documents or files “false or misleading returns.”65 When the burden of proof is on the tax administrator, the taxpayer is not required to prove that its transfer pricing is authentic until the tax administrator proves a “prima facie” case that the “pricing is inconsistent with the arms length principle.”66 Another approach to transfer pricing legislative provisions with respect to the burden of proof is the simple requirement that taxpayers cooperate with tax administrators. In such a case, failure to cooperate will permit the tax administrator to estimate the income of the taxpayer and will permit the tax administrator to presume certain applicable and relevant facts. However, the OECD’s Transfer Pricing Guidelines recommends that tax administrators not be enabled by law to use methods that would make it too difficult for cooperation.67 As for penalties the OECD Transfer Pricing Guidelines recommends that civil penalties only be such that is necessary to realize the revenue lost by non-compliance or abuse of transfer pricing techniques.68 The OECD Transfer Pricing Guidelines 2001 specifically asks that Member States apply any penalty in a fair manner which should take account of whether or not the penalty is “proportionate to the offence.”69 There are a number of guidelines within the OECD’s Transfer Pricing Guidelines as well as the OECD’s Model Tax Convention that can provide a good basis for Freedonia and Atlantica to draft transfer pricing legislation. These guidelines are designed to reduce the incidents of transfer pricing manipulation so that tax administrators are not denied the appropriate revenues due. Tax Liabilities for SuperOffice Inc, Hillary and Air-Atlantica a. SuperOffice Inc. In the event Freedonia and Atlantica adopt a bilateral tax treaty based on the OECD Tax Treaty Model, SO’s primary tax liabilities will be to Atlantica since it has what is defined as a permanent establishment in that country. It appears from the facts that SO meets the Article V criteria since it has in Atlantica “a fixed place of business through which the business is wholly or partly carried on”.70 A similar scenario exists in Freedonia, although under the UN model the maintaining of a warehouse will not qualify as a permanent establishment. Even so, as a foreign business, SO will benefit from the holiday clause in which it will not be required to pay income tax in Freedonia for a period of four years. Upon the expiration of four years, SO will be liable to pay taxes in respect of all profits derived from Freedonia, since it will be operating part of its business there in the form of marketing, public relations and sales. Taxes payable to Atlantica will only be applied to all profits on sales made in Atlantica while the taxes applicable in Freedonia will only be attached to profits derived from sales in Freedonia. However the maximum tax rate applicable in Freedonia will be fixed at 10%.71 b. Hillary Hillary is exposed to double taxation on her holiday home in Freedonia and her family home in Atlantica. The treaty tiebreaker as contained in Article IV(3) of the OECD Tax Treaty Model 2008 is no real assistance to her since it provides for the place of effective management to be deemed her residence. Hillary maintains a business in Atlantica and this might be taken into account when determining her residence. Even so, whether or not Hillary is a resident of Atlantica, she is liable to pay taxes on the home that is located there.72 By virtue of Article VI of the OECD a resident in one Contracting State is duty bound to pay taxes on immovable property owned in the other Contracting State. As for the series of lectures, Hillary will not be bound to pay taxes on any remuneration or wages paid to her for the lectures if the lectures are not conducted for a period exceeding 183 days.73 However, the fee paid to Hillary’s company for the lectures in Freedonia are not taxable in Freedonia unless it Hillary’s company has a permanent establishment in that country and if she did, only income derived from that actual establishment would be taxable. c. Air-Atlantica AA will benefit from the four years holiday clause in the OECD Tax Treaty Model between Freedonia and Atlantica. However upon the expiration of the four years holiday clause AA will be taxed in accordance with the provisions contained in Article X of the OECD Tax Model 2008. The projected profits and annual profits will be taxed at 15 % on gross income in respect of intercompany dividends at a maximum but will be reduces to 5% if the 25 percent of the company’s capital is held by its parent company.74 In any event at the end of the four year period, AA will be regarded as a business with a permanent establishment in Freedonia since it will be carrying on business there in a substantial way. In this regard, Freedonia will be entitled to collect taxes as the primary tax principle in respect of the catering services and the leasing projects conducted in that jurisdiction.75 Atlantica may tax the interests since it is the home of AA. The applicable taxes will be assessed at a maximum of 10%. 76 Bibliography Abdullah, W. (2004)Critical Concerns in Transfer Pricing and Practice. Praeger Publishers. 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(1998) Tax Law Design and Drafting. Vol. 2. International Monetary Fund. UN Tax Treaty Model. Van den Berg, J. and van der Gulik, B. (May 4, 2009) “The Mutual Agreement Tiebreaker – OECD and Dutch Perspectives”. Tax Notes International, 417-428. Weeghel, S. (1998) The Improper Use of Tax Treaties: With Particular Reference to the Netherlands and the United States. Kluwer Law International. Read More