1、2)The federal government,state government and local government of the USA have pretty rights to collect taxes,while the rights to collect taxes are mostly controlled in central government.3)The USA use comprehensive income tax system and deduct fees refers to different use itemized income tax system
2、.4)In the respect of estate tax, real estate tax is the mainly object to be taxed .differences among Macau,China Continent and HongKong for the purpose of tax features according to table 11)The corporate income tax rates in China Continent is the highest in these three ,to 25%.The tax base of China
3、Continent Is worldwide while the others areterritorial.t have them.resident ),while the others donof3)China Continent have value- added tax ,while the others dondifferences among UK,China Continent and Spain for the purposeCorporate income tax according to table 2 1)Spain has the highest corporate t
4、ax rate to %.2)UK doesnt tax for many income which China Continent or Spain will taxmanagement fees.purpose of withholding taxes according to table 3and1)For branch profits, interest ,technical fees and management fees mostjurisdictions dont collect tax except Ireland(collect for interest)China Cont
5、inent.2)Except Switzerland federal tax rates of dividends and interest are 35%and higher than China Continent,other jurisdictions withholding taxrates are mostly lower or equal to China Continent.Chapter2International Income Taxation does a country generally design its income taxation system(book pa
6、ge50)1)territorial( 领土模式): 2)Residency( 属人模式) : tax on the worldwide income of residents, and impose tax on the income of nonresidents from certain sources within the country. USA.3)Exclusion( 例外) : specific inclusion or exclusion of certain amounts,classes,or items of income in/from the base of tax
7、ation.4)Hybrid( 混合模式 ): some governments have chosen for all or only certain classes of taxpayers, to adopt systems that are a combination of territorial, residency, or exclusionary.is it important to make clear source of incomeTo make clear source of income is important because it decidides that wh
8、ether a individual or corporation should pay tax in a country and what credits can it enjoy.tax Credit;Withholding tax;explanation:Thin Capitalization;ForeignInternational tax treaty; Deferral system; International transfer pricingThin Capitalization:Thin capitalization is a method that taxpayers bo
9、rrow too much money from oversea related party and pay much interest, so that they can enjoy much deduction before this way,they transfer profits from high tax burdencountries to low tax burden countries or jurisdictions.Foreign tax Credit (外国税收抵免) :If you paid or accrued foreign taxes to a foreign
10、country on foreign source income and are subject to resident country tax on the same income, you may be able to take a credit for those taxes.Taken as a credit, foreign income taxes reduce your own country tax liability.Withholding tax:Withholding tax is tax withheld by the country when a corporatio
11、n making a payment to its resident country , in which the full amount owed to that corporation is reduced by the tax withheld.International tax treaty:International tax treaty is a treaty a country (or jurisdiction) signed with other countries (or jurisdiction) for affairs about taxation.Deferral sy
12、stemresidence to make investment broad.International transfer pricing:International transfer pricing is a very important way for multinationalcompany to avoid international tax.Transfer pricing refers to a kind of non-market pricing action taken byrelated corporations to shift profits form high tax
13、rate countries orjurisdictions to low tax rete regions.Chapter3Tax Residenceis the main difference between a tax resident and a non-tax resident fortax liability purposeIn general, a tax resident bears infinite tax liability ,should pay taxfor all of its income.A non-tax resident bears limited tax l
14、iability, should pay tax for incomesourced from the country.you name some tests in determining whether a person is a residentfor corporation:shareholders test for individiual: a fact-and-circumstances test ;abode test; number of dayChin a:15year - temp orary reside nt,5year - Ion g-term reside nt)test(into judgean example to prove how different countries apply differing tests a persons residenceFor example ,China for individual:domicile test,number of days(a full year);ir
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