消除国际双重征税方法对纳税人、各国政府以及资本变动带来什么影响.ppt

Double Taxation Relief 1 Deduction Method 2 Exemption Method 3 Credit Method 4 Other Methods 居住国政府应征所得税额=（居民的国内国外所得-已纳外国所得税额）*适用税率 Full Exemption method Progressive Exemption method In such systems, the foreign-source income is initially included in income for the limited purpose of determining the average tax rate at which the taxpayer would pay if the foreign-income were taxable. This average rate is then used to compute the actual tax due on the taxpayers’s other income. Taxpayers If the foreign taxes are lower than domestic taxes, resident taxpayers are treated more favorably than other residents. Taxpayers have a strong incentive to move the funds to a foreingn country that imposes low or no taxes. It may shift tax burdens from the income earner to the income payers. Governments The exemption method completely eliminates residence-source international double taxation. The country of residence may have a loss on tax revenue. A partial exemption system can minimizes compliance costs for tax authorities. Capital flow An exemption system encourages resident taxpayers to invest abroad in countries with lower tax rates, especially in tax havens, and it encourages them to divert domestic-source income to such countries. The reduction method allows foreign income tax rate lower than their normal tax rate (ie special off tax rate ) for cross-country taxpayers already paid foreign tax . Features of this method is that after cross-income taxpayers in foreign tax treatment after repatriation, their government tax again in a rate that is lower than the normal tax rate . Example 　　a multinational taxpayers get $ 1 million in revenue from country A, A national income tax rate is 30%. A tax rate applicable to the taxpayers home country where 50% of its cross-country portion of the taxpayer repatriate foreign income tax rate of 10 percent by levying special offers, then the part of the taxpayer to obtain a tax amount is? Holdover Method As the name suggest