List and explain three main conflict which can lead to international double taxation??
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ChatGPT
Jul 19
1. Residence-based taxation vs. source-based taxation: Residence-based taxation is when a country taxes its residents on their worldwide income, regardless of where the income is earned. Source-based taxation is when a country taxes income earned within its borders, regardless of the taxpayer's residency. When a taxpayer is subject to both residence-based and source-based taxation, it can lead to double taxation.
2. Conflicting tax treaties: Countries often enter into tax treaties to prevent double taxation and promote cross-border trade and investment. However, conflicting provisions in tax treaties between two countries can lead to double taxation. For example, if one country considers a taxpayer to be a resident based on its domestic laws, while the other country considers the taxpayer to be a resident based on the tax treaty, double taxation can occur.
3. Differences in tax laws and regulations: Variations in tax laws and regulations between countries can also lead to double taxation. For example, one country may allow certain deductions or exemptions that are not recognized by another country, resulting in the same income being taxed twice. Additionally, differences in the timing of recognizing income or expenses can also lead to double taxation.
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Google Gemini AI
Jul 19
1. Conflict of Source and Residence:
- This arises when two countries claim taxing rights over the same income based on where the income is earned (source) and where the taxpayer resides. - For example, if a corporation earns income from a branch in a foreign country, the income may be taxable in both the foreign country (source) and the home country (residence).
2. Conflict of Characterization:
- This occurs when different countries classify the same type of income differently. - For example, dividends may be treated as income from capital in one country and as business income in another, leading to different tax treatments.
3. Conflict of Credit and Exemption:
- This relates to how countries avoid double taxation. - The credit method allows taxpayers to claim a tax credit for taxes paid to the foreign country against their home country taxes. - The exemption method excludes foreign-sourced income from taxation in the home country. - If countries have different methods of avoiding double taxation, it can lead to situations where taxes are either not fully credited or completely exempted, resulting in potential double taxation.