| revenue procedure (rev. proc.) | An official published statement by the irs of us about procedural and administration aspects of the tax laws. |
| proprietorship | - An unincorporated business owned by a single person. the individual proprietor has the right to all the profits from the business and also the responsibility for all its liabilities.
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| license duties (or fee) | Annual duties payable for the privilege of carrying on a certain trade. |
| undistributed profits tax | Annual tax imposed, in addition to the normal corporate income tax, on the undistributed portion of the profits or surplus of a corporation. |
| research and development (r&d) | - Any systematic or intensive study carried out in the manufacturing and industrial field, the results of which are to be used for the production or improvement of products and processes.
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| tax-free zone | Area within the territory of a country in which customs duties and other types of indirect taxes are not applied. |
| provisional assessment | Assessment of tax made before it is possible to make a final assessment which is often based on, for example, estimated figure or the previous year`s figures. |
| life interest | Assets may be given to a person for his lifetime use or benefit, with the stipulation that after his (the life tenant`s) life, the asset will pass to another beneficiary. |
| business assets | Assets used for purposes of carrying on a business |
| bapa | Bilateral advance pricing arrangement. also called map apa. map apa; |
| stripped bond | - Bond or debenture from which the interest coupons have been removed and sold separately.
- Bond that can be subdivided into a series of zero-coupon bonds.
- Чистое долговое о...
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| in kind | - Broadly speaking, a distribution or payment other than in money.
- В материальной форме
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| non-resident | Broadly speaking, a person who spends most of the calendar year outside his country of domicile. non-residents are usually taxed on income derived from sources within the taxing jurisdiction where... |
| short-term capital gains | Capital gain derived from the disposal of assets which have been held for a comparatively short period of time. |
| portfolio interest | Category of interest that may be paid from us sources free of withholding tax provided certain requirements are met. the portfolio interest exemption does not apply to bank loans made in the ordin... |
| pool basis | Collective basis for the purpose of depreciation of business assets falling within the same category. for example, all depreciable assets of a similar kind are effectively treated as a single asse... |
| fiscal nullity doctrine | Common law doctrine used in the uk in cases of avoidance of tax, whereby certain transactions are ignored for fiscal purposes. cf. substance over form doctrine. |
| subsidiary company | Company effectively controlled by another company (i.e. the parent company). a variety of criteria, including share ownership ratio, may be employed to determine whether one company is a subsidiar... |
| multinational enterprises (mne) | Company or group of companies with business establishments in two or more countries. |
| base company | Company situated in a low-tax or non-tax country (i.e. tax haven), which is used to shelter income and reduce taxes in the taxpayer`s home country. base companies carry on certain activities on be... |
| multiple captives | Company which has more than one captive insurance company. |
| auxiliary company | Company which is part of a group of companies and which supplies auxiliary services to group companies. |
| service company | Company within a multinational group of companies which generally provides support services, such as administration, sales information, post-sales service or market research, for the operating div... |
| regulated investment company (ric) | Company, also known as a mutual fund, formed under us law to make diversified investment with funds provided by investors who receive dividends and capital gains realized by ric. |
| personal holding company | Company, the shares of which are principally owned by or attributed to the taxpayer, and which is set up to receive his investment income. |
| presumptive taxation | Concept of taxation according to which income tax is based on "average" income instead of actual income. |
| force of attraction | Concept under which a permanent establishment is taxed by the country in which it is located not only on the income and property, but also on all income derived by its foreign head office from sou... |
| revenue neutrality | Constraints on tax reform that it should not change revenues available to government in any significant way. |
| foreign currency option | Contract with an option to buy/sell foreign currency. see: option. |
| cost funding | Contribution of an affiliate company to the general research and development (r&d) costs of another affiliate or group member, in proportion to its turnover or some other criterion |
| domestic corporation | Corporation which is organized or has its place of effective management in a country. |
| world wide income | Criterion for the income tax liability of a resident company or individual of a certain country. in many countries a resident company or individual is subject to corporate/individual income tax on... |
| net working capital | Current assets less current liabilities. |
| information return | Declaration made by a person who has economic information about a potential taxpayer, regardless of whether that person is liable for withholding tax. |
| lump-sum deductions | Deduction, often from income, for the computation of taxable income, which does not reflect the factual situation. |
| ministry of finance (mof) | Department of government generally responsible for formulating monetary policy, implementing the tax laws, collecting revenue, etc. |
| direct investment | - Description often given to a substantial investment in the shares of a company.
- The purchase of a controlling interest in a company or at least enough interest to have enough influe...
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| shifting an incidence of taxation | Determination of the economic entity that actually ends up paying a particular tax. in the case of indirect taxation tax is normally intended to fall upon consumption and be borne by consumers, so... |
| hardship clause | Discretionary power of the tax authorities to mitigate any harsh results of the tax law. |
| intercorporate dividends | Dividends distributed between two companies (domestic or foreign) arising from a shareholding or participation in the capital of the paying company. |
| upstream dividend | Dividends flowing from a subsidiary company to its parent company. |
| substance over form doctrine | Doctrine which allows the tax authorities to ignore the legal form of an arrangement and to look to its actual substance in order to prevent artificial structures form being used for tax avoidance... |
| horizontal equity | - Doctrine which holds that similarly situated taxpayers should receive similar tax treatment, e.g. taxpayers who earn the same amount of income or capital should be accorded equal treatment. горизонтальное равенство;
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| tax clearance certificate | Document issued to a taxpayer by the tax authorities certifying that the taxpayer has either paid all taxes due or that he is not liable to any taxes. in certain countries a tax clearance certific... |
| double taxation, domestic and international | Domestic double taxation arises when comparable taxes are imposed within a federal state by sovereign tax jurisdictions of equal rank. international double taxation arises when comparable taxes ar... international double taxation; |
| double taxation, economic and juridical | Double taxation is juridical when the same person is taxed twice on the same income by more than one state. double taxation is economic if more than one person is taxed on the same item. juridical double taxation; |
| tax bill | - Draft law on a tax matter which, after approval by the government of a country, is submitted to the parliament for debate.
- Amount of money owed for taxes
- Amount of money ...
налоговый счет; |
| stamp duties | Duty levied upon the issue of official documents such as passports, deeds, contracts for the transfer of ownership, etc. usually, stamp duties are "levied" by way of a stamp being fixed to the doc... |
| hybrid entity | Entity that is characterized differently in two or more jurisdictions, for example, an entity that is treated as a partnership in one jurisdiction and as a corporation in another. |
| green card | - Entry document issued by the us immigration and naturalization service (ins) that permits foreign nationals to live permanently in the us and undertake employment.
- The common name f...
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| privileged tax regime | Euphemism for the tax regime of a tax haven. |
| premium at the issue of shares | Excess of issue value over par value in issuing corporate shares. it is a contribution to capital and not taxed as profits. |
| foreign currency futures | Exchange traded contract for the delivery of a standardized amount of foreign currency on a specific future date. the price for the foreign currency is agreed on the day the contract is bought or ... |
| index-linked adjustment | Expedient adopted in many commercial transactions to provide a workable solution to some of the problems created by inflation and monetary depreciation. the mechanism is essentially one of adjusti... indexation; |
| investment incentives | Financial and tax incentives used to attract local or foreign investment capital to certain activities or particular areas in a country. |
| hybrid derivative | Financial instrument which has the characteristic of more than one type of instrument, i.e. a swap plus an option. hybrid instrument; |
| registration duty | Fixed or variable duty levied on documents which relate to the transfer of ownership or the right to use movable or immovable property, the formation or any change of status of a company, etc. |
| lump-sum exempt amounts | Fixed sum of income, net worth, etc., below which no tax is due. |
| fob value | Fob denotes "free on board". fob value is value of goods excluding carriage, insurance and freight, i.e. roughly speaking, the domestic price in the country of origin. |
| tax burden | For public finance purposes the tax burden, or tax ratio, in a country is computed by taking the total tax payments for a particular fiscal year as a fraction or percentage of the gross national p... |
| place of management | For purposes of the application of a tax treaty, the place of management of an enterprise normally forms a permanent establishment. the term "place of management" as such is not defined in the oec... management, place of; |
| frontier workers | For tax purposes, a frontier worker is a person who commutes across a border (e.g. on a daily basis) between his place of residence and his place of employment. |
| recovery of tax | From the taxpayer`s point of view, this may mean a refund of tax. from the tax authorities’ point of view, it may mean the collection of tax which is in arrears. |
| speculative gains | Gains from the disposal of capital assets which were originally acquired with a view to selling them for more than the cost of acquisition. |
| affiliated companies | General term used to describe the relationship between two or more companies linked by a common interest |
| turnover tax | - General term used to refer to the different forms of consumption and sales taxes.
- Налог с оборота
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| foreign-source income | Generally income realized from countries outside the country of residence of the taxpayer. |
| tax exile | - Generally speaking, a natural or legal person who severs all ties which make him fiscally resident in a particular country and moves to another jurisdiction for tax reasons.
- Выезд п...
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| associated enterprises | Generally speaking, enterprises are associated where the same persons participate directly or independently in the management, control or capital of both enterprises, i.e. both enterprises are und... |
| management expenses | Generally the expenses of management are deductible in arriving at the taxable profits of an enterprise carrying on a trade. in the case of a group of companies it may be important to decide how f... |
| good faith | - Good faith denotes a state of mind, whereby a person honestly and truly believes that certain facts or circumstances are as he says they are.
- Добросовестность
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| white paper | - Government document announcing government policy and practice on a specific issue or issues.
- Правительственный информационный документ по какому-либо вопросу подробный или авторитет...
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| unilateral relief | Granting of relief from the effects of international double taxation on the basis of domestic legislation rather than the provisions of a tax treaty. |
| resale price margin | Gross margin measured by reference to the price at which goods purchased from another party are resold to independent enterprises. |
| deemed interest | If a member of a multinational enterprise (mne) receives an interest-free loan from an affiliated company, the tax authorities of the lender`s country may readjust the lender`s profits by adding a... |
| imputed interest | - Implied interest. in a mortgage that states an insufficient interest rate, tax law will impute a higher rate and a lower principal, which will increase taxes on the receipt of payment.
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| forfait | In a number of countries tax is sometimes levied on an estimated taxable base (forfait), particularly in respect of the imposition of income tax or turnover tax on small enterprises. |
