第21章必讲后备国际税收环境与转移定价
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Value-added tax is easier to administer as well. While taxpayers have an incentive to hide their income, producers have an incentive to make sure that their upstream suppliers in the production process declare the value added (and pay the tax!).
21-8
Corporate Percentage Income Tax Rates in Selected Countries
21-9
Withholding Tax
Withholding taxes are withheld（扣缴） from the payments a corporation makes to the taxpayer.
Branch and Subsidiary Income Payments to and from Foreign Affiliates Tax Havens Controlled Foreign Corporation Transfer Pricing & Related Issues Blocked Funds（冻结资金）
international tax environment.
Fourth Edition
本章对跨国公司税收筹划很有用，对从事国际金融资产投资
也很有指导意义。
EUN / RESNICK
21-1
Chapter Outline
The Objectives of Taxation Types of Taxation The National Tax Environments（国别税收环境） Organizational Structures for Reducing Tax Liabilities
Income Tax Withholding Tax Value-Added Tax
21-6
Income Tax
An income tax is a tax on personal and corporate income.
Many countries in the world obtain a significant portion （很大一部分）of their tax revenue from income taxes.
21-15
Value-Added Tax Calculation
Production Stage
1 2 3
Selling Price
€100 €300 €380
Value Added
€100
€200 €80
Incremental VAT
€15 €30
€12
= €100 .15 = €200 .15 = €80 .15
the sale of inventory from the retailer to the consumer.
21-16
Other Types of Taxation
A wealth tax is a tax levied not on income but on the wealth of a taxpayer. Property taxes are an example.
的方式征税。
21-4
Tax Equity
Tax Equity: regardless of the country in which an affiliate of a MNC earns taxable income（无论跨国公司的分公司从 哪个国家取得的应税所得）, the same tax rate and tax due date should apply（适用相同的税率和纳税日期）. 例如，跨国公司的国外分公司所赚到的1美元与国内分 公司所赚到的1美元应按相同的规则纳税。
哪个国家，东道国对该跨国公司的分公司所征收的税收应该一视同仁且应 与本国企业相同。
3. National Neutrality: taxable income is taxed in the same manner by the taxpayer’s national tax authorities regardless of where in the world it is earned. 不论应税所得是在世界哪个国家挣的，各国税收当局都应以同样
In many European and Latin American countries the value-added tax has become a major source of taxation on private citizens.
Many economists prefer a value-added tax to an income tax because the incentive effects of the two taxes differ sharply.
2. Capital Import Neutrality: the tax burden on a MNC subsidiary should be the same regardless of where in the world the MNC is incorporated（子 公司的税负不因母公司所在地的不同而有所区别）. 无论跨国公司属于
21-12
U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries
21-13
Value-Added Tax
A value-added tax is an indirect tax levied on the value added in production of a good or service.
An income tax is a direct tax, that is one that is paid directly by the taxpayer upon whom it is levied（被征收）.
21-7
Corporate Percentage I Countries
Allows taxpayers to recover somewhat from double taxation. Direct foreign tax credits are computed for direct taxes paid on active foreign-source income of a foreign branch of a U.S. MNC or on withholding taxes withheld from passive income. Indirect foreign tax credits are for income taxes paid by the subsidiary.
21-19
Territorial Taxation
Territorial taxation tax（征税，这里是动词） residents based upon where the taxable event occurred.
21-20
Foreign Tax Credits
美国选择的避免双重征税的方式，是对跨国公司来自外国的收入 已向外国当局缴纳的税款进行抵扣，即不再对这部分收入按照美 国税制征税。外国税收抵扣总额不应高于假设这部分外国收入发 生在美国的纳税额。税收抵扣的最高额度以全世界外国来源所得 计算，发生在不同国家的损益可以相互冲销，某一税收年度未抵 扣完的可以回抵过去1年和未来10年的税收。
The principal of tax equity is difficult to apply; the organizational form of the MNC can affect the timing of the tax liability.
21-5
Types of Taxation
Worldwide Taxation（全球性税制） Territorial Taxation（地区性税制） Foreign Tax Credits（国外税收抵扣）
21-18
Worldwide Taxation
Tax national residents of the country on their worldwide income no matter in which country it was earned.
1. Capital Export Neutrality: the tax scheme does not incentivise citizens move their money abroad. 好的税制既能为政府有效地筹集收入，又不会
对纳税人的经济决策产生负面影响，不会阻碍资源配置到世界任何可获得 最高回报率的地方。资本输出中性是建立在实现全球经济效率基础上的。
A withholding tax is an indirect tax.
21-10
U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries
21-11
U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries
21-2
The Objectives of Taxation
The twin objectives of taxation are: 1. Tax Neutrality （税收中性） 2. Tax Equity（税收公平）
21-3
Tax Neutrality
A tax scheme is tax neutral if it meets three criteria:
A poll tax（人头税，投票税） is a tax on your existence. It is so called because it was collected from those who wished to vote.
21-17
The National Tax Environments
21-14
Value-Added Tax
An income tax has the incentive effect of discouraging work.
A value-added tax has the incentive effect of discouraging consumption (thereby encouraging saving).
INTERNATIONAL FINANCIAL
MANAGEMENT
21-0
International Tax
21
Environment
Chapter
INTERNATTIwOenNty-AonLe
Chapter Objective:
FINANCIAL
MANAGEMENT
This chapter provides a brief introduction to the
Total VAT
€57
= €380 .15
In this example, the tax rate is 15 percent. Suppose that stage
one is the sale of raw materials to the manufacturer; stage
two is the sale of finished goods to a retailer; stage three is
The taxes are levied on passive income earned by an individual or corporation of one country within the tax jurisdiction（税收管辖权） of another country.
Passive income includes interest income and dividends, income from royalties（特许权收入）, patents, or copyrights.
21-8
Corporate Percentage Income Tax Rates in Selected Countries
21-9
Withholding Tax
Withholding taxes are withheld（扣缴） from the payments a corporation makes to the taxpayer.
Branch and Subsidiary Income Payments to and from Foreign Affiliates Tax Havens Controlled Foreign Corporation Transfer Pricing & Related Issues Blocked Funds（冻结资金）
international tax environment.
Fourth Edition
本章对跨国公司税收筹划很有用，对从事国际金融资产投资
也很有指导意义。
EUN / RESNICK
21-1
Chapter Outline
The Objectives of Taxation Types of Taxation The National Tax Environments（国别税收环境） Organizational Structures for Reducing Tax Liabilities
Income Tax Withholding Tax Value-Added Tax
21-6
Income Tax
An income tax is a tax on personal and corporate income.
Many countries in the world obtain a significant portion （很大一部分）of their tax revenue from income taxes.
21-15
Value-Added Tax Calculation
Production Stage
1 2 3
Selling Price
€100 €300 €380
Value Added
€100
€200 €80
Incremental VAT
€15 €30
€12
= €100 .15 = €200 .15 = €80 .15
the sale of inventory from the retailer to the consumer.
21-16
Other Types of Taxation
A wealth tax is a tax levied not on income but on the wealth of a taxpayer. Property taxes are an example.
的方式征税。
21-4
Tax Equity
Tax Equity: regardless of the country in which an affiliate of a MNC earns taxable income（无论跨国公司的分公司从 哪个国家取得的应税所得）, the same tax rate and tax due date should apply（适用相同的税率和纳税日期）. 例如，跨国公司的国外分公司所赚到的1美元与国内分 公司所赚到的1美元应按相同的规则纳税。
哪个国家，东道国对该跨国公司的分公司所征收的税收应该一视同仁且应 与本国企业相同。
3. National Neutrality: taxable income is taxed in the same manner by the taxpayer’s national tax authorities regardless of where in the world it is earned. 不论应税所得是在世界哪个国家挣的，各国税收当局都应以同样
In many European and Latin American countries the value-added tax has become a major source of taxation on private citizens.
Many economists prefer a value-added tax to an income tax because the incentive effects of the two taxes differ sharply.
2. Capital Import Neutrality: the tax burden on a MNC subsidiary should be the same regardless of where in the world the MNC is incorporated（子 公司的税负不因母公司所在地的不同而有所区别）. 无论跨国公司属于
21-12
U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries
21-13
Value-Added Tax
A value-added tax is an indirect tax levied on the value added in production of a good or service.
An income tax is a direct tax, that is one that is paid directly by the taxpayer upon whom it is levied（被征收）.
21-7
Corporate Percentage I Countries
Allows taxpayers to recover somewhat from double taxation. Direct foreign tax credits are computed for direct taxes paid on active foreign-source income of a foreign branch of a U.S. MNC or on withholding taxes withheld from passive income. Indirect foreign tax credits are for income taxes paid by the subsidiary.
21-19
Territorial Taxation
Territorial taxation tax（征税，这里是动词） residents based upon where the taxable event occurred.
21-20
Foreign Tax Credits
美国选择的避免双重征税的方式，是对跨国公司来自外国的收入 已向外国当局缴纳的税款进行抵扣，即不再对这部分收入按照美 国税制征税。外国税收抵扣总额不应高于假设这部分外国收入发 生在美国的纳税额。税收抵扣的最高额度以全世界外国来源所得 计算，发生在不同国家的损益可以相互冲销，某一税收年度未抵 扣完的可以回抵过去1年和未来10年的税收。
The principal of tax equity is difficult to apply; the organizational form of the MNC can affect the timing of the tax liability.
21-5
Types of Taxation
Worldwide Taxation（全球性税制） Territorial Taxation（地区性税制） Foreign Tax Credits（国外税收抵扣）
21-18
Worldwide Taxation
Tax national residents of the country on their worldwide income no matter in which country it was earned.
1. Capital Export Neutrality: the tax scheme does not incentivise citizens move their money abroad. 好的税制既能为政府有效地筹集收入，又不会
对纳税人的经济决策产生负面影响，不会阻碍资源配置到世界任何可获得 最高回报率的地方。资本输出中性是建立在实现全球经济效率基础上的。
A withholding tax is an indirect tax.
21-10
U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries
21-11
U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries
21-2
The Objectives of Taxation
The twin objectives of taxation are: 1. Tax Neutrality （税收中性） 2. Tax Equity（税收公平）
21-3
Tax Neutrality
A tax scheme is tax neutral if it meets three criteria:
A poll tax（人头税，投票税） is a tax on your existence. It is so called because it was collected from those who wished to vote.
21-17
The National Tax Environments
21-14
Value-Added Tax
An income tax has the incentive effect of discouraging work.
A value-added tax has the incentive effect of discouraging consumption (thereby encouraging saving).
INTERNATIONAL FINANCIAL
MANAGEMENT
21-0
International Tax
21
Environment
Chapter
INTERNATTIwOenNty-AonLe
Chapter Objective:
FINANCIAL
MANAGEMENT
This chapter provides a brief introduction to the
Total VAT
€57
= €380 .15
In this example, the tax rate is 15 percent. Suppose that stage
one is the sale of raw materials to the manufacturer; stage
two is the sale of finished goods to a retailer; stage three is
The taxes are levied on passive income earned by an individual or corporation of one country within the tax jurisdiction（税收管辖权） of another country.
Passive income includes interest income and dividends, income from royalties（特许权收入）, patents, or copyrights.