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The Relationship Between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties : New Zealand Case

2018
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Release : 2018
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Book Synopsis The Relationship Between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties : New Zealand Case by : B.J. Arnold

Download or read book The Relationship Between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties : New Zealand Case written by B.J. Arnold. This book was released on 2018. Available in PDF, EPUB and Kindle. Book excerpt: This article discusses a recent New Zealand Court of Appeal case involving the relationship between New Zealand's CFC rules and the tax sparing provision in the China-New Zealand Income Tax Treaty (1986). The Court rejected the taxpayer's claim on the basis of a narrow, literal interpretation of the elimination of double taxation article of the treaty.

The Taxation of Controlled Foreign Corporations

1987 Corporations, Foreign
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Release : 1987
Genre : Corporations, Foreign
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Book Synopsis The Taxation of Controlled Foreign Corporations by : John Prebble

Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble. This book was released on 1987. Available in PDF, EPUB and Kindle. Book excerpt: Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.

New Zealand Taxpayer Entitled to Foreign Tax Credit for Tax Sparing Granted to Controlled Foreign Company

2017
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Release : 2017
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Book Synopsis New Zealand Taxpayer Entitled to Foreign Tax Credit for Tax Sparing Granted to Controlled Foreign Company by : K.J. (Kevin) Holmes

Download or read book New Zealand Taxpayer Entitled to Foreign Tax Credit for Tax Sparing Granted to Controlled Foreign Company written by K.J. (Kevin) Holmes. This book was released on 2017. Available in PDF, EPUB and Kindle. Book excerpt: This note summarizes the New Zealand High Court decision in Lin v. Commissioner of Inland Revenue, which entitled a New Zealand-resident taxpayer with relevant interests in certain controlled foreign companies in China to a foreign tax credit for both tax paid in China by the controlled foreign companies and to tax spared in China arising from tax concessions granted to those companies.

New Zealand Taxpayer Not Entitled to Foreign Tax Credit for Tax Sparing Granted to Controlled Foreign Company

2018
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Release : 2018
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Book Synopsis New Zealand Taxpayer Not Entitled to Foreign Tax Credit for Tax Sparing Granted to Controlled Foreign Company by : K.J. (Kevin) Holmes

Download or read book New Zealand Taxpayer Not Entitled to Foreign Tax Credit for Tax Sparing Granted to Controlled Foreign Company written by K.J. (Kevin) Holmes. This book was released on 2018. Available in PDF, EPUB and Kindle. Book excerpt: This note summarizes the New Zealand Court of Appeal's decision in Commissioner of Inland Revenue v. Lin, which overturned the High Court's 2017 ruling that a New Zealand-resident taxpayer with relevant interests in certain controlled foreign companies in China was entitled to a foreign tax credit for both tax paid in China by the controlled foreign companies and to tax spared in China arising from tax concessions granted to those companies.

Controlled Foreign Company Legislation

1996 Business & Economics
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Release : 1996
Genre : Business & Economics
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Book Synopsis Controlled Foreign Company Legislation by : Organisation for Economic Co-operation and Development

Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development. This book was released on 1996. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.

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