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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.

Transfer tax

When discussing the topic of taxation, it is important to understand the concept of transfer tax. This type of tax is imposed on the exchange of goods and rights, such as th...

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Alienation of income

One often hears the term "transfer of income rights" in the realm of finance. This refers to the process of transferring the right to receive income from a source without ne...

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Private ruling

A tax ruling is a decision made by tax authorities for an individual taxpayer, typically pertaining to a specific transaction or set of transactions. It is important to note...

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Negative income tax

In the realm of finance, there exists a potential solution for aiding those living in poverty through the utilization of existing income tax structures. This proposed approa...

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