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MEMORANDUM OF Knowing (MOU)  -- Within the context of the tax treaty, a document exchanged between the treaty companions which sets out the understanding of the get-togethers regarding the convention. Usually this does not have treaty position, but the status depends upon the document itself.

JOINT VENTURE  -- Term and that is loosely employed to describe a romance among get-togethers carrying on an enterprise in common for his or her specific or popular gain. This can be possibly an incorporated enterprise or an unincorporated venture.

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ROLLOVER RELIEF  -- Aid through which liability to money gains tax is deferred. The vital characteristic of roll-over aid is usually that a achieve which might normally have arisen within the prevalence of a taxable celebration for capital gains tax purposes is deferred, or rolled over, until finally There's a subsequent  disposal from the asset concerned.

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ENVIRONMENTAL TAX -- Tax imposed for environmental motives, e.g. to deliver an incentive to lower specific emissions to an ideal level or taxes on environmentally harmful solutions.

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RESIDENT ALIEN  -- A person is said to be a resident alien of a rustic if he resides in that region but is actually a citizen of An additional country.

ATTRIBUTION Procedures  -- Regulations that make possession by attributing inventory to 1 social gathering Despite the fact that the shares are legally owned by One more party; frequently referred to as constructive possession of stock.

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Independent TAXATION  -- Separate taxation can be a technique of taxing a married pair on The premise of their joint income.

Some international locations take care of a partnership like a separate taxpayer and should matter it to tax on its income and losses as a company. Other international locations usually do not take into consideration a partnership being a individual lawful entity as well as the partnership is handled as tax visit our website transparent, with Every single specific companion currently being taxed on his share with the income In line with his desire within the partnership. Taxation of partnerships is tackled in the Commentary to Report one of the OECD Design.

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BALANCING PAYMENT  -- A payment, Typically from one or more participants to another, to adjust individuals’ proportionate shares of contributions, that enhances the worth of the contributions of your payer and decreases the worth of your contributions in the payee by the go to my site amount of the payment, in the context of CCA (Expense Contribution Preparations).

HARDSHIP CLAUSE  -- Discretionary electrical power of the tax authorities to mitigate any severe benefits of the tax legislation.

RETROACTIVE EFFECT  -- The outcome of tax law provision toward the past, which can be allowed only to the advantage of a taxpayer.

Desired destination PRINCIPLE  -- Basic principle below a VAT regime which mandates that VAT on goods be compensated while in the nation where by the purchaser is resident (i.e. the region of usage) at the rate that could have used had the products been acquired from a domestic provider.

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EQUAL Remedy -- Standard principle of taxation that needs that taxpayers shell out an equal degree of tax if their conditions are equivalent.

SHAREHOLDER Action  -- An action which is performed by a member of an MNE group (ordinarily the guardian corporation or a regional Keeping business) solely thanks to its possession fascination in a number of other team associates, i.e. in its ability as shareholder.

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