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Sia · 2020年10月12日

问一道题:NO.PZ2018091705000051

问题如下:

Discuss three potential double taxation conflicts in which two countries claim to have taxing authority over the same income or assets.

选项:

解释:

The interaction of countries’ taxation jurisdictions can create tax conflicts in which Country A and B can claim to have authority to tax the same investment properties. This conflict can arise in three ways:

Residence  residence conflict: If he were a resident of both countries, Country A and B would both claim residence of Mr. Lloyd, subjecting his worldwide income to taxation by both countries.

Source  source conflict: Both Country A and B may claim source jurisdiction of the same investment properties as income from the investments that are in Country A, but managed from Country B.

Residence  source conflict: Because Lloyd lives in Country B, but has investment properties in Country A, he may be subject to a combination of two taxation jurisdictions. As a resident of Country B he could be taxed on worldwide income; and if Country A exercises source jurisdiction on his assets, he will be taxed on these as well. In this case, the source country (Country A) is commonly viewed to have primary jurisdiction to tax income within its borders and the residence country (Country B) is expected to provide double taxation relief.

请问答案最后一句话provide double taxation relief是什么意思呢?

1 个答案

王暄_品职助教 · 2020年10月13日

嗨,爱思考的PZer你好:


provide double taxation relife就是说:B国提供了双重税收的减免


-------------------------------
虽然现在很辛苦,但努力过的感觉真的很好,加油!


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