| general partner | - In a partnership, a partner whose liability is not limited. all partners in an ordinary partnership are general partners. a limited partnership must have at least one general partner and at le...
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| minimum tax | In certain countries corporations are always liable to a certain amount of annual tax, regardless of whether they have realized a profit. |
| benefit test | In considering whether a company may be allowed to deduct, as an expense, payments made to a related company in a multinational group on account of expenses incurred by that related company in pro... |
| long-term capital gains | In countries where capital gains are subject to special tax treatment, a distinction may be made between capital gains realized after a short period of time and capital gains realized after a long... |
| federal tax | In federal states, taxation may exist on two levels: taxation by the federation or confederation, and taxation by the state or provinces. |
| possessions of u.s. | In general, any us island, cay or reef that is not part of any of the 50 states. for tax purposes, possessions include puerto rico, the virgin islands, the marshall islands, the federated states o... |
| small traders, special tax regime for | In many countries small traders are subject to a special tax regime, particularly in respect of vat, in which exemption, lower tax burden or lower administrative burden are granted. |
| reduced rates | In many countries the ordinary rates of tax charged under various tax laws may be reduced in particular situations. for example, under tax treaties, reduced withholding tax rates often apply to di... |
| gross income, taxes on | In some countries income taxes are levied on gross income (usually at low rates) without deduction for expenses. |
| taxpayer identification number | - In some countries taxpayers are given an identification number which must be used when filing a tax return and assessing taxes and for all other correspondence between the taxpayer and the tax...
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| lump-sum rates | In specific cases, income tax (and other taxes) may be levied at a fixed rate instead of the rates usually applicable. |
| quarantining | In the context of the foreign tax credit system, this term denotes the separate calculation of the foreign tax payable on all foreign income of a particular category which may be credited against ... |
| habitual abode | In the context of the tie-breaker rule of the oecd model tax treaty, habitual abode is one of the criteria used to resolve the problem of dual residence. it refers to the period of time a taxpayer... |
| itemized deductions | In the us a deduction as specifically set forth in the internal revenue code. the deductions in this part are individually listed, item by item. |
| option to be taxed | In the vat context, a vat exempt entrepreneur sometimes can claim to be subject to vat, the advantage being that to be entitled to his input tax against his output tax. |
| passive income | - Income in respect of which, broadly speaking, the recipient does not participate in the business activity giving rise to the income, e.g. dividends, interest, rental income, royalties, etc.
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| income shifting | Income splitting |
| fixed income | Income which does not fluctuate over a period of time, such as interest on bonds and debentures, or dividends from preference shares as opposed to dividend income from ordinary shares. |
| luxury taxes | Indirect ad valorem tax imposed on supplies of specific non-essential and normally expensive commodities that are arbitrarily considered (e.g. toiletries, cosmetics, jewellery, pearls and precious... |
| multi-stage tax system | Indirect tax charged on the same goods at successive stages of production and distribution. |
| hidden tax | - Indirect tax paid by the consumer without his knowledge.
- Косвенный налог
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| repatriation | - Individuals and legal entities investing their capital in a foreign country in order to derive income from such capital may wish to transfer this capital or income back to their home country, ...
репатриация; |
| tax form | It is usual to design special forms for taxpayers to declare their taxable income, sales, etc. for tax purposes. forms are designed to facilitate the task of the tax authorities in assessing and c... forms, tax; |
| real property (real estate) | Land and everything more or less attached to it. also referred to as “realty”. |
| unimproved property | Land that has received no development, construction, or site preparation (i.e. raw land). |
| per capita | Latin for "for each person" на душу населения; |
| pro rata | - Latin for "proportionally"
- Shared or divided according to a ratio or in proportion to participation.
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| internal revenue code (irc) | Legislation passed by us congress that specifies what income is to be taxed, how it is to be taxed, and what may be deducted from taxable income. |
| tax threshold | Level (of income, capital, sales, etc.) at which tax commences to be levied. |
| unlimited liability | - Liability of an investor which extends to the full extent of his personal assets, as in the case of a sole proprietor or general partner.
- Full liability for the debt and other oblig...
неограниченная ответственность; |
| limited liability | - Liability of investor which is limited to the extent of his investment
- Restriction of shareholders‘ losses to the amount of capital they have invested in a company. see limited comp...
ограниченная ответственность; |
| zero coupon bond | Long-term bond on which interest is not payable on a regular basis, but rather upon maturity of the bond. it is sold at a deep discount from its face value. deep discount bond; |
| fiscal transparency | Looking through an entity and attributing profits and losses directly to the entity`s members. the profits of certain forms of enterprises are taxed in the hands of the members rather than at the ... |
| temporary importation | - Many countries allow temporary importation without levying customs duties and turnover tax on items which are to be within their borders for only a short time.
- Customs regime under ...
временный ввоз; |
| net worth tax | Many european countries impose the net worth tax in the context of property taxation. the taxable base for resident taxpayers is normally the taxpayer`s worldwide net worth, i.e. total assets less... net wealth tax; |
| invoice basis | Method of applying vat to the price at which the goods or service are invoiced, with a deduction for the tax (if any) charged at previous stages. |
| back-to-back loan | - Method of borrowing between related parties where a loan is channelled through an independent third-party intermediary.
- A loan in which two companies in separate countries borrow ea...
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| accounting basis | Method of calculating amounts subject to income tax and vat. in respect of vat, tax would be computed as a percentage levy on the excess of sales over purchases. this is a theoretical concept and ... |
| single entity approach | Method of taxing a legal entity that conducts its business through a permanent establishment rather than through a subsidiary company. under the single entity approach, a head office and a permane... |
| profit mark-up | Method to find an arm`s length price, by taking the vendor`s cost and adding an appropriate profit mark-up. |
| investment method | Method used in connection with vat where an immediate credit is granted against tax for that part of expenditure incurred during the year for acquisition of business assets (such as plant and mach... |
| resale price method | Method used in transfer pricing between affiliated companies, under which an arm`s length price is ascertained by deducting a normal profit margin from the resale price at which a buyer of invento... |
| profit method | Method used in transfer pricing cases that looks at the profits arising from controlled transactions of one or more of the associated enterprises participating in such transactions. |
| loss relief | Most income tax laws provide some form of relief for losses incurred, either by carrying over the loss to offset it against profits in previous years (carry-back) or in future years (carry-forward... |
| exchange of information | Most tax treaties contain a provision under which the tax authorities of one country may request the tax authorities of the other country to supply information on a taxpayer. information may only ... |
| mutual assistance | Mutual assistance in the context of tax treaties is that one of the contracting states will collect taxes due to the other contracting state. see optional article 27 of the oecd model. |
| franchise taxes | Nearly all states in the us levy an annual franchise tax on resident and non-resident corporations for the privilege of the right to do business in that state. |
| tax secrecy | Obligation usually imposed on tax officials not to reveal particulars about the identity and personal circumstances of taxpayers, or about any of the various aspects governing their tax liability,... |
| administrative office | Office frequently located in a country other than that of the headquarters office, the parent company or country of operation. |
| offshore bank | Offshore banking business basically consists of borrowing in foreign currencies for non-resident depositors outside the country and relending the foreign currencies to other non-residents. a numbe... |
| nexus link. | Often a requirement in tax law for determination of taxability or deductibility. for example, expenses are deductible if they have a “nexus” with gross income. in us, the taxable income of a multi... |
| income property | - Often, real estate that is bought for the income it produces.
- Real estate purchased for the reasons of income generation.
доходная недвижимость; |
| apportionment method | One of the methods used to allocate income and expenses between related enterprises using a formula consisted of some factors such as sales, property, or payroll. |
| ordinary shares | - Ordinary shares (also known as common stock) are generally shares with an equal par value and bear equal rights and obligations such as the right to participate in the management of the compan...
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| publicly traded limited partnership (ptlp) | Partnership in the us that is listed and traded on an established stock exchange or a secondary market. with some exceptions, ptlps are taxed in the us as corporations rather than partnerships. |
| severance payments | Payment made as a result of the termination of any office or employment of a person. |
| dual residence | Person or company resident in two or more countries under the law of those countries, because the two countries adopt different definitions of residence. |
| personal allowances | Personal allowances are granted to individuals as deductions from income in computing their taxable income. there is usually a deduction for the individual himself, spouse, children and other depe... |
| place of effective management | Place of effective management is the test suggested in the tie-breaker rule of the oecd model tax treaty to determine the residence of a company where under the domestic laws of both contracting s... management, place of effective; |
| round trip transaction | Potential transfer pricing abuse where intangible property is developed by a parent company which licenses it to a related party manufacturer located in a low-tax jurisdiction. the manufactured go... |
| one hundred and eighty-three (183) days` rule | Presence in a country for 183 days or more in any 12-month period may have tax consequences, particularly in respect of an individual`s residence for tax purposes or for the taxation of employment... six months` rule; |
| extended limited tax liability | Principle according to which certain taxpayers (i.e. those subject to individual income tax, net worth tax and succession duty) who leave a tax jurisdiction and move to a low-tax country are subje... |
| residence principle of taxation | Principle according to which residents of a country are subject to tax on their worldwide income and non-residents are only subject to tax on domestic-source income. |
| source principle of taxation | Principle for the taxation of international income flows according to which a country consider as taxable income those income arising within its jurisdiction regardless of the residence of the tax... |
| origin principle | Principle under a vat regime where goods are taxed in the country where they are produced, i.e. they are taxed on the basis of their place of production or origin. |
| destination principle | Principle under a vat regime which mandates that vat on goods be paid in the country where the purchaser is resident (i.e. the country of consumption) at the rate that would have applied had the g... |
| arbitrage, tax | Process of entering into a tax motivated transaction (i.e. to obtain profit from the application of tax rules). |
| pre-tax profits | Profit after deducting depreciation, costs, etc., but before deducting taxes. |
| intangible property | - Property which has no physical existence but which has a value based on a legal right of the owner, e.g. goodwill, patent, trade mark, copyright, software, inventions, designs, i.e. all manner...
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| tangible property | Property with a physical form, e.g. personal property, real property as distinguished from intangible property. |
| source rule | Provision in the national law of a country or in a tax treaty which defined the concept of source for a particular type of income. |
| situs rule | Provision of tax law setting out the factors which determine where a particular asset is situated or deemed to be situated for tax purposes. |
| bank secrecy provisions | Provisions which require that a bank refuse to disclose information about its customers to third parties, including the tax authorities. |
| gross profit ratio | Ratio of gross profit to the sales of a business or, alternatively, to the adjusted purchases or "goods consumed" during the accounting period. |
| net profit margin | - Ratio of operating profits to gross income (or revenue)
- A measure of trading profit relative to sales revenue calculated by dividing profit after interests and taxes by sales revenu...
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| berry ratio | Ratio used to establish an arm`s length profit. the berry ratio is the ratio of a business` gross income to operating costs. |
| insurance settlement | - Receipt of proceeds of an insurance policy.
- The payment of proceeds by an insurance company to the insured to settle an insurance claim within the guidelines stipulated in the insur...
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