必讲后备 国际税收环境与转移定价培训教程文件.pptVIP

Chapter Outline The Objectives of Taxation The twin objectives of taxation are: Tax Neutrality 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。 The principal of tax equity is difficult to apply; the organizational form of the MNC can affect the timing of the tax liability. Types of Taxation Income Tax Withholding Tax Value-Added Tax 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. 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）. Corporate Percentage Income Tax Rates in Selected Countries Corporate Percentage Income Tax Rates in Selected Countries Withholding Tax Withholding taxes are withheld（扣缴） from the payments a corporation makes to the taxpayer. 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. A withholding tax is an indirect tax. U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries U.S. Tax Treaty Percentage Withholding Tax Rates with Selected Countries Value-Added Tax A value-added tax is an indirect tax levied on the value added in production of a good or service. 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. Value-Added Tax An income tax has the incentive effect of discouraging work. A value