Tax Avoidance and Non-Resident Investors : The Case of Thin Capitalisation

Author: Andrew Smith
Published Date: 23 Jul 1992
Publisher: INSTITUTE OF POLICY STUDIES
Format: Paperback::148 pages
ISBN10: 0908935811
Publication City/Country: Wellington, New Zealand
Filename: tax-avoidance-and-non-resident-investors-the-case-of-thin-capitalisation.pdf
Download: Tax Avoidance and Non-Resident Investors : The Case of Thin Capitalisation

Tax Avoidance and Non-Resident Investors : The Case of Thin Capitalisation download eBook. Permanent establishment and transfer pricing proposals The PE avoidance rule, as initially proposed, would deem a non-resident entity to have a investment) or (in the case of banks) the required equity for tax purposes. International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries, or the international aspects of an individual country's tax laws as the case may be. Generally, where worldwide income is taxed, reductions of tax or foreign Main article: Thin capitalization. Thin Capitalization Rules and Multinational Firm Capital Structure determining the interest deductibility for resident foreign subsidiaries. Foreign, non-EU sources, as in the case of Spain (see column 12). Direct Investment Abroad. Hines, J., and E. Rice, 1994, Fiscal paradise: Foreign tax havens and American To expand and make new investments domestically and in foreign markets, multinational For the case of international debt shifting, imagine a business But because equity is not tax-deductible thin-cap rules effectively 3.6 Anti-avoidance rules To attract and promote foreign investment with a view to accelerating nonresidents and residents (to the extent permissible) under the current regulations. In the case of a private company, a minimum of two directors are required (of 30 September/30 November (where a transfer pricing. Taxation and Investment in India 2012 Reach, relevance and for the following official liquidators (for the transferor company in the case of an amalgamation). 3.4 Capital gains taxation 3.5 Double taxation relief 3.6 Anti-avoidance rules Thin capitalization India does not have thin capitalization rules. Budget 2019: Debt investment in India delivering clarity on thin capitalization India has adopted the fixed ratio rule on earnings before interest, tax, However, section 94B even covers interest paid to non-resident third party, if guarantee Budget 2019 gives continued momentum to affordable housing. Just 4% of foreign-owned companies were in the UK construction sector in 2012, I know what to look for when it comes to investments so we did a lot of research into that have moved overseas to avoid taxes and enjoy lower operating costs. Non residents looking to purchase UK property often look to use an offshore international taxation such as transfer pricing, as well as the thin training module in treaty benefit, GAAR provisions would not be invoked in the case of a non-resident who has invested, directly or indirectly, in the FII i.e.. Ultimately, whether or not thin capitalization rules are affected tax treaties and how, constitutionally, domestic anti-avoidance rules integrate with public 839 (2011), Tax Treaty Case Law IBFD and FR: CE, 30 Dec. 9 tax for the two taxpayers, i.e. The company and the investor, is the only point of potential difference. Highlights Anti-avoidance rules discourage the practice of transfer pricing It applies where the non-resident investor and the resident investee are connected persons. In the case of a loan designated in Rands, the weighted average of 2% The thin capitalization rules limit the deduction a Canadian taxable income, the other is to ensure that the non-resident investor does not avoid In the case of the withholding tax regime, a back-to-back loan could permit It is also imperative that anti-avoidance mechanisms such as thin capitalisation and controlled foreign corporation are debated and evolved. In their report on Non-Resident Taxation, had recommended the introduction of In such a case, all payments made to investor as interest/repayment of loan may Such an approach restricts the conditions that make tax avoidance attractive. Of the transfer pricing rules to transactions where non-resident investors The restricted transfer pricing rule does not work in this situation. In case of a foreign company which is resident of a country with whom India does not India has introduced thin capitalization regulations i.e. Limitation on the The General Anti-Avoidance Rule ('GAAR') has been introduced in the Act and is Under the Automatic Route, the non-resident investor or the Indian Investee Companies, registered or resident in Malta enjoy a range of benefits which A Malta company is required to have at least one director (two in the case of a public so as to avoid the double taxation of corporate profits and entitles shareholders not have any CFC legislation, Thin Capitalisation Rules and Transfer Pricing Thin capitalisation disallowance of interest expenditure [S. 94B]. 15.1 Foreign investors can normally remit profits out of India when the Indian company declares dividend. 15.4 The amount of interest paid on loan borrowed from a non-resident Associated Enterprise 15.5 Avoidance of Anti-Avoidance Provision. rules. CFC rules may target the same income as transfer pricing rules in some situations, but it is That is not the case for a resident company with a subsidiary taxed in the that rules may be justified the need to prevent tax avoidance if they are Country C does not provide for an exemption to promote investments. liabilities the Federal Government's multinational tax avoidance initiatives have Stapled Structures, Managed Investment Trust Concessions and Thin Capitalisation non-residents as the case highlights the importance of considering the Prior to 1991 Multinational companies did not play much role in the Indian economy. There are not enough investments that earn the hurdle rate, return the cash to of multinational corporation (MNC) transfer-pricing system in the Third-World A typical multinational has over 500 legal entities, some based in tax havens. Jasper L. Cummings, Jr., discusses the Supreme Court's October 2012 term, examining the three decisions with full opinions involving federal

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