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跨国公司的国际税务筹划英文文献和翻译

更新时间:2014-11-13:  来源:毕业论文

Abstract.

Globalization tends to open new era of transnational Corporation, where the determination of tax bases has become very technical. Tax can either be imposed on the basis of incorporation of accompany or on the basis of the income that can be attributed to a particular territory. The three main areas of conflict in determining the tax bases of Transnational Corporations are 1) allocation of profits between associated enterprises, 2) trade between associated enterprises and 3) determination of permanent establishment of transnational corporations. But all these systems are with some loopholes which ultimately leads to tax evasion. Tax planning is a legitimate device used by the companies to save tax but this device should not be used with the intention to evade tax.

Keywords: Globalization, tax planning, tax avoidance


In wake of globalization there has been a tremendous surge in the corporate world, it is the era of Trans National Corporations (hereinafter referred as TNC). Battling against multi jurisdiction and stringent tax regimes, lot of them are adopting ways and means to condense their tax liability. Since rate of tax varies and margin of tax is wide in some cases, TNC’s have been resorting to devices to shift income from one jurisdiction to
another, so  as  to  classify it  differently. Devices such  as  ‘transfer pricing’, ‘treaty

shopping’, ‘thin capitalization’  are some of the most prominent practices adopted. It becomes very complex for the authorities to figure out and prove evasion of tax because of the strategic planning of the MNCs. We all know that a substantial portion of revenue collected in a state is because of the imposition of tax on corporates and individuals on
their income. But recent economic developments, particularly the globalization of capital markets, have made enforcement of national income taxes increasingly difficult. These enforcement issues go beyond mere tax competition for real economic activities; because of 本文来自六.维,论-文·网原文请找腾讯324-9114 income that could not be earned anywhere other than within their borders. A primary cause of this difficulty lies in the failure to devise effective methods of taxing the domestic income of foreign corporations. Often,
such income ends up subject to taxation only in low or no-tax jurisdiction. A very thin2692

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