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Qualification of Taxable Entities and Treaty Protection

出版	Sdu Uitgevers, 2014
ISBN	90123926089789012392600
URL	http://books.google.com.hk/books?id=nRyYoAEACAAJ&hl=&source=gbs_api

註釋

The qualification of entities as taxpayers is of significant importance in tax law. First, the status is relevant when determining whether an entity is actually subject to corporate income taxation in a certain country. Second, recognition of the entity as a taxable one will often have the effect that the income derived at the level of the entity is only taxed in the hands of the entity rather than being attributed to the owners/shareholders "behind" the entity. The treatment of a domestic entity as transparent or non-transparent is a policy decision to be made by probably all tax jurisdictions. This IFA report deals first with the issue how entities are classified under the domestic tax laws of the branch reporters' jurisdictions. The second part will focus on how countries actually deal with qualification conflicts. The book contains a general report and several branch reports.