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moon · 2021年06月19日

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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.

这道题能不能用中文回答一下呢? 太绕了

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王暄_品职助教 · 2021年06月20日

属人-属人:Lloyd同时是两个国家的居民,且A国和B国都施行属人政策,那么Lloyd的收入都被A国征收一遍,然后被B国征收一遍。


属地-属地:A国和B国都施行属地政策。例如Lloyd有资产在A国,那么资产所产生的收益首先要被A国征一笔税;由于管理资产的公司处于B国,那么这笔收入也算来源于B国,所以此时,B国正对这笔资产也要收税。


属人-属地:这就是最常见的。假设Lloyd是A国人,在B国工作,且A国实行属人政策,B国实行属地政策。那么Lloyd在B国的收入,首先被B国收税,接着又会被A国收税。

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