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山风泽笑 · 2021年11月13日

请问这是double taxation知识点吗？

  1. CFA III
  2. 个人IPS

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.

老师您好，请问这是框架里的Credit method, exemption method和deduction method这三种方法吗？谢谢！

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王暄_品职助教 · 2021年11月13日

本题是关于double taxation的知识点，但并不是说的这三种方法，只是让你写出三种冲突，可能会导致双重征税现象：

这种题目是属于基础的定性题，自己说先要理解“residence-residence”、“source—source”、“residence-source”的意思。然后按照自己的理解，把他写出来，让判卷子的人读的懂即可。我写一个我的给你看看：

Residence-residence: If he were residence of both country A and B, and both countries claim a residence tax jurisdiction, then his worldwide income will be subjected by both countries.

Source-source: If he were residence of both country A and B, and both countries claim a source tax jurisdiction. Then the investment properties in country A but managed in country B will be subjected to tax of both countries.

Residence-source: As a resident of country B and if country B applies a residence jurisdiction, his worldwide income will be subject to tax of country B; and if Country A exercises source jurisdiction on his assets, his income from Country A will be subject to tax of country A as well.


而你说的method，是减免税收的三种方法。

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