Explanation of Proposed Income Tax Treaty Between the United States and the Slovak Republic: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993 |
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accordance activities addition allow amount apply arising Article attributable avoid basis benefits branch profits tax business profits carried competent authority conduct contains coun country of residence cover deductions defined definition determining dividends paid domestic double taxation earnings effectively connected enterprise entity establishment or fixed example exchange exempt extent fixed base foreign corporation foreign tax credit gains gross imposed income derived income tax treaties independent personal services individual interest investment limitation mean OECD model operation organization paragraph payments percent performance period permanent establishment permit present proposed treaty proposed treaty contains provisions real property received recipient regard resi resident respect royalties rules saving clause securities shares similar situated Slovak Slovakia source country source income specific taxable term tion trade or business treaty country U.S. citizen U.S. income tax U.S. model treaty U.S. source U.S. tax United unless withholding tax
Populāri fragmenti
11. lappuse - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
8. lappuse - Convention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other...
56. lappuse - State; c) to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public).
4. lappuse - dividends" as used in this Article means income from shares, "jouissance" shares or "jouissance" rights, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.
56. lappuse - State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Convention. Such persons or authorities shall use the information only for such purposes.
5. lappuse - royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films...
23. lappuse - resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.
21. lappuse - ... means any body corporate or any entity which is treated as a body corporate for tax purposes; f) the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State...
20. lappuse - citizen" shall include a former citizen whose loss of citizenship had as one of its principal purposes the avoidance of tax, but only for a period of 10 years following such loss.
17. lappuse - Treaties generally provide for the exchange of information between the tax authorities of the two countries when such information is necessary for carrying out provisions of the treaty or of their domestic tax laws. The obligation to exchange information under the treaties typically does not require either country to carry out measures contrary to its laws or administrative practices or to supply information...
Bibliogrāfiskā informācija
| Nosaukums | Explanation of Proposed Income Tax Treaty Between the United States and the Slovak Republic: Scheduled for a Hearing Before the Committee on Foreign Relations, United States Senate, on October 27, 1993 |
| Atbalstītāji | United States. Congress. Senate. Committee on Foreign Relations, United States. Congress. Joint Committee on Taxation |
| Izdevējs | U.S. Government Printing Office, 1993 |
| ISBN | 016041718X, 9780160417184 |
| Apjoms | 58 lappuses |
| Eksportēt avotu | BiBTeX EndNote RefMan |