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Old Westbury campus ​many countries have agreed with other countries in treaties to mitigate the effects of double taxation tax treaties may cover income taxes inheritance taxes value-added taxes or other taxes besides bilateral treaties also multilateral treaties are in place countries of the European Union have also entered into a multilateral agreement with respect to value-added taxes under auspices of the EU while a joint treaty on mutual administrative assistance of the council of europe and the oecd exists open to all nations tax treaties tend to reduce taxes of one treaty country for residents of the other treaty country in order to reduce double taxation of the same income the provisions and goals very highly very few tax treaties are alike most treaties define which taxes are covered and who is a resident and eligible for benefits reduce the amounts of tax withheld from interest dividends and royalties paid by a resident of one country to residents of the other country limit tax of one country on business income of a resident of the other country to that income from a permanent establishment in the first country define circumstances in which income of individuals resident in one country will be taxed in the other country including salary self-employment pension and other income provide for exemption of certain types of organizations or individuals and provide procedural frameworks for enforcement and dispute resolution the stated goals for entering into a treaty often include reduction of double taxation eliminating tax evasion and encouraging cross-border trade efficiency it is generally accepted that tax treaties improve certainty for taxpayers and tax authorities in their international dealings several governments and organizations have proposed model treaties to use as starting points in their own negotiations the organization for economic cooperation and development model treaty is often used as such a starting point the OECD members have from time to time agreed on various provisions of the model treaty and the official commentary and member comments thereon serve as a guidance as to interpretation by each member country tax residency in general the benefits of tax treaties are available only to persons who are residents of one of the treaty countries in most cases a resident of a country is any person that is subject to tax under the domestic laws of that country by reason of domicile residents place of incorporation or similar criteria generally individuals are considered resident under a tax treaty and subject to taxation where they maintain their primary place of abode however residence for treaty purposes extends well beyond the narrow scope of primary place of abode for example many countries also treat persons spending more than a fixed number of days in the country as residents the United States includes citizens and green card holders wherever living as subject to taxation and therefore as residents for tax treaty purposes because residence is defined so broadly most treaties recognize that a person could meet the definition of residence in more than one jurisdiction and provide a a euro ort breaker applause such clauses typically have a hierarchy of three to five tests for resolving multiple residency typically including permanent abode as a major factor tax residency rarely impacts citizenship or permanent resident status though certain residency statuses under a country's immigration law may influence tax residency entities may be considered resident based on their country of seat of management their country of organization or other factors the criteria are often specified in a treaty which may enhance or override local law it is possible under most treaties for an entity to be resident in both countries particularly where a treaty is between two countries that use different standards for residence under their domestic law some treaties provide a euro oet breaker or euro rules for entity residency some do not residency is irrelevant in the case of some entities and/or types of income as members of the entity rather than the entity are subject to tax permanent establishment most treaties provide that business profits of a resident of one country as subject to tax in the other country only if the profits arise through a permanent establishment in the other country many treaties however address certain types of business profits separately such treaties also define what constitutes a permanent establishment most but not all tax treaties follow the definition of PE in the OECD model treaty under the OECD definition a PE is a fixed place of business through which the business of an enterprise is carried on certain locations are specifically enumerated as examples of PE s including branches offices workshops and others specific exceptions from the definition of PE are also provided such as a site where only preliminary or ancillary activities are conducted while in general tax treaties do not specify a period of time for which business activities must be conducted through a location before it gives rise to a PE most OECD member countries do not find a PE in cases in which a place of business exists for less than 6 months absent special circumstances many treaties explicitly provide a longer threshold commonly one year or more for which a construction site must exist before it gives rise to a permanent establishment in addition some treaties most commonly those in which at least one party is a developing country contain provisions which dima PE to exist if


certain activities are conducted for certain periods of time even where a PE would not otherwise exist even where a resident of one county does not conduct its business activities in another country through a fixed place or business a PE may still be found to exist in that other country where the business is carried out through a person in that other country that has the authority to conclude contracts on behalf of the resident of the first country thus a resident of one country cannot avoid being treated as having a PE by acting through a dependent agent rather than conducting its business directly however carrying on business through an independent agent will generally not result in a PE withholding taxes many tax systems provide for collection of tax from non-residents by requiring pairs of certain types of income to withhold tax from the payment and remit it to the government such income often includes interest dividends royalties and payments for technical assistance most tax treaties reduce or eliminate the amount of tax required to be withheld with respect to residents of a treaty country income from employment most treaties provide mechanisms eliminating taxation of residents of one country by the other country where the amount or duration of performance of services is minimal but also taxing the income in the country performed where it is not minimal most treaties also provide special provisions for entertainers and athletes of one country having income in the other country though such provisions very highly also most treaties provide for limits to taxation of pension or other retirement income tax exemptions most treaties eliminate from taxation income of certain diplomatic personnel most tax treaties also provide that certain entities exempt from tax in one country are also exempt from tax in the other entities typically exempt include charities pension trusts and government-owned entities many treaties provide for other exemptions from taxation that one or both countries as considered relevant under their governmental or economic system harmonization of tax rates tax treaties usually specify the same maximum rate of tax that may be imposed on some types of income as an example a treaty may provide that interest earned by a non-resident eligible for benefits under the treaty is taxed at no more than five percent however local law in some cases may provide a lower rate of tax irrespective of the treaty in such cases the lower local law rate prevails provisions unique to inheritance taxes generally income taxes and inheritance taxes are addressed in separate treaties inheritance tax treaties often cover estate and gift taxes generally fiscal domicile under such treaties is defined by reference to domicile as opposed to tax residence such treaties specify what persons and property are subject to tax by each country upon transfer of the property by inheritance or gift some treaties specify which party bears the burden of such tax but often such determination relies on local law most inheritance tax treaties permit each country to tax domiciliaries of the other country on real property situated in the taxing country property forming a part of a trade or business in the taxing country tangible movable property situated in the taxing country at the time of transfer and certain other items most treaties permit the estate or donor to claim certain deductions exemptions or credits in calculating the tax that might not otherwise be allowed to non domiciliaries double tax relief nearly all tax treaties provide a specific mechanism for eliminating it but the risk of double taxation is still potentially present this mechanism usually requires that each country grant a credit for the taxes of the other country to reduce the taxes of a resident of the country the treaty may or may not provide mechanisms for limiting this credit and may or may not limit the application of local law mechanisms to do the same mutual enforcement taxpayers may relocate themselves and their assets to avoid paying taxes some treaties thus require each treaty country to assist the other in collection of taxes and other enforcement of their tax rules most tax treaties include at a minimum a requirement that the country's exchange of information needed to foster enforcement tax information exchange agreement the purpose of this agreement is to promote international cooperation in tax matters through exchange of information it was developed by the OECD global forum working group on effective exchange of information the working group consisted of representatives from OECD member countries as well as delegates from Aruba Bermuda Bahrain Cayman Islands Cyprus Isle of Man Malta Mauritius the Netherlands Antilles the Seychelles and San Marino the agreement grew out of the work undertaken by the OEC d to address harmful tax practices the lack of effective exchange of information is one of the key criteria in determining harmful tax practices the Mandate of the working group was to develop a legal instrument that could be used to establish effective exchange of information the agreement represents the standard of effective exchange of information for the purposes of the o ekta euro unregistered trade mark s initiative on harmful tax practices this agreement which was released in april two thousand two is not a binding instrument but contains two models for bilateral agreements a number of bilateral agreements have been based on this agreement dispute resolution nearly all tax treaties provide some mechanism under which taxpayers and the countries can resolve disputes arising under the treaty generally the government agency responsible for conducting dispute resolution procedures under the treaty is referred to as the a euro OE competent authority o of the country competent authorities generally have the power to bind their government in specific cases the treaty mechanism often calls for the competent authorities to attempt to agree in resolving disputes limitations on benefits recent treaties of certain countries have contained an article intended to prevent treaty shopping which is the


inappropriate use of tax treaties by residents of third states these limitation on benefits articles de neither benefits of the tax treaty to residents that do not meet additional tests limitation on benefits articles vary widely from treaty to treaty and are often quite complex the treaties of some countries such as the United Kingdom and Italy focus on subjective purpose for a particular transaction denying benefits where the transaction was entered into in order to obtain benefits under the treaty other countries such as the United States focus on the objective characteristics of the party seeking benefits generally individuals and publicly traded companies and their subsidiaries are not adversely impacted by the provisions of a typical limitation of benefits provision in a US tax treaty with respect to other entities the provisions tend to deny benefits where an entity seeking benefits is not sufficiently owned by residents of one of the treaty countries even where entities are not owned by qualified residents however benefits are often available for income earned from the active conduct of a trade or business priority of law treaties are considered the supreme law of many countries in those countries treaty provisions fully override conflicting domestic law provisions for example many EU countries could not enforce their group relief schemes under the EU directives in some countries treaties are considered of equal weight to domestic law in those countries a conflict between domestic law and the treaty must be resolved under the dispute resolution mechanisms of either domestic law or the treaty external links pension tax relief Australian tax treaties Barbados tax treaties Canada income tax treaties Dutch tax treaties Mauritius tax treaties Singapore tax treaties United Kingdom tax treaties US income tax treaties list of u.s. estate and gift tax treaties the exchange of tax information portal notes American Academy of Dramatic Arts.

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