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HG · 2021年01月13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.

老师这三种是对应的啥知识点?

2 个答案

王暄_品职助教 · 2021年01月15日

考试的时候会有上午题吗?这个描述好复杂啊。。。


2021年都改为了客观题、主观题。客观题为essay题,也就是之前的上午题;主观题为选择题,也就是之前的下午提。

这个考点可能出主观题,同学还是需要把握。但不用像书上写的这么复杂,掌握概念,能分得清,会计算即可。

王暄_品职助教 · 2021年01月13日

是关于double taxation,请看基础班讲义R30里,最后三页PPT。

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