Flashcard: International Taxation Fundamentals — 18 carte

International Taxation — definition?

Taxation of cross-border income and assets.

Taxable Event — role?

Triggers tax liability across borders.

Double Taxation — issue?

Same income taxed by two countries.

Tax Treaty — purpose?

Allocate rights, prevent double taxation.

Source vs Residence — difference?

Source: where income arises; Residence: taxpayer’s home country.

OECD and UN Models — roles?

Guidelines for treaties; OECD favors residence, UN favors source.

Tax Treaty Content — includes?

Definitions, scope, allocation, dispute resolution.

Tax Residency — importance?

Determines primary taxing country.

French Tax System — hierarchy?

Treaties > Domestic law > Regulations.

French Domestic Rates — individuals?

Progressive, up to 45%.

French Domestic Rates — companies?

Flat 25% corporate rate.

Double Taxation — methods to eliminate?

Credits or exemptions.

OECD Model — favor?

Residence-based taxation.

UN Model — favor?

Source-based taxation, especially for developing countries.

Tax Treaty — scope?

Income, capital, defined persons, and taxes.

Tax Residency — dual?

Resolved by tie-breaker rules in treaties.

Permanent Establishment — role?

Threshold for source taxation of business profits.

Mutual Agreement Procedure — purpose?

Resolve treaty disputes.