scholarly journals Opportunities for tax planning for digital companies: international experience

2021 ◽  
Vol 14 (2) ◽  
pp. 214-222
Author(s):  
A. S. Alekseev
Keyword(s):  
Great Britain ◽  
Income Tax ◽  
Rapid Development ◽  
International Experience ◽  
Tax Planning ◽  
It Industry ◽  
Tax Rate ◽  
Foreign Countries ◽  
Key Features ◽  
The One

The article deals with comparing taxation conditions of a range of countries which can be applied for IT companies as the subjects of digital economy. The author examines the peculiar features of tax privileges, tax planning tools and optimization for running digital companies in such countries as Estonia, Hong Kong, Great Britain, Malta and Ireland. These countries are included in a number of international ratings and are highly estimated by foreign experts as regards the level of convenience of doing IT business. The author especially focuses on the financial calculations of possible ways for tax optimization and the key features of implementation of the extremely popular in European countries IP-Box regimes. In conclusion the author concentrates on the patterns and trends within the tax jurisdictions under consideration including the one regarding the existing treaties on avoiding double taxation. He points out that it is possible to use the international experience in order to create competitive taxation of digital companies in Russia as part of developing addenda to the package of measures (effective 01.01.2021) which is also called “tax maneuver”. In particular, it is suggested that income tax rate for IT businesses in Russia should be altered taking into consideration the foreign countries’ indexes. Moreover, the author presents his ideas on the components of possible use of such measures as “digital residency” as part of the second package of “tax maneuver” measures. The author makes a conclusion on the importance of implementing non-taxation measures for maintaining rapid development of IT-industry in Russia and enumerates the most essential directions and problems of the IT-society and the possible ways of their realization.

scholarly journals Beneficial ownership of income as an antiabusive measure in Serbian Tax Law

2020 ◽  
Vol 59 (88) ◽  
pp. 217-232
Author(s):  
Miloš Vasović
Keyword(s):  
Income Tax ◽  
Corporate Income Tax ◽  
Tax Law ◽  
Tax Rates ◽  
Double Taxation ◽  
Current Function ◽  
Tax Rate ◽  
Treaty Shopping ◽  
Beneficial Ownership ◽  
The One

The Serbian Corporate Income Tax Act contains a provision on the beneficial ownership of income (hereinafter: the BO provision), which is one of the conditions for the application of the preferential tax rate on income tax after tax deduction, which is envisaged in Treaties for the avoidance of Double Taxation on income and capital (hereinafter: Double Taxation Treaties/ DTTs). The subject matter of research in this paper is the term "beneficial ownership", which is not defined in the Corportate Income Tax Act. It may ultimately lead to abusing the preferential tax rates from the DTTs in tax planning and "treaty shopping" through the use of conduit companies. Tax experts have different opinions on the legal nature of the BO provision, which is given the function of an anti-abusive measure (on the one hand) and a rule for the attribution of income (on the other hand). The author analyzes the current function of the BO provision envisaged in the Serbian Serbian Corporate Income Tax Act (CITA), and its inadequate application. The author advocates for enacting the BO provision as an anti-abusive measure, and examines the possible application of the BO provision in domestic tax law, with reference to Articles 10, 11, and 12 of the DTTs that Serbia contracted with other states, as well as Articles 10-12 of the OECD Model-Convention on Income and Capital (2017) and Commentaries on these articles. Such an application of the BO provision may preclude "treaty shopping". In final remarks, the author points out why the BO provision should be envisaged as an anti-abusive measure in Serbian tax law.

scholarly journals PENERAPAN TAX PLANNING TERHADAP PPh SEBAGAI UPAYA EFISENSI PEMBAYARAN PAJAK (Studi Kasus Pada Perusahaan Jasa Angkutan Di Malang)

IQTISHODUNA ◽  
2011 ◽  
Vol 4 (2) ◽  
Author(s):  
Nanik Wahyuni
Keyword(s):  
Income Tax ◽  
Tax Planning ◽  
Observational Result ◽  
Corporate Tax ◽  
Tax Rate ◽  
Shift Cost ◽  
New Firm ◽  
Branch Office ◽  
Cost Shift ◽  
Taxation Problem

To the effect of observational it is subject to be to insofar know which income tax planning effectiveness that can be done by firm and to reach efficiency in paying taxes charges that shall pay firm. Base observational result and taxation problem study in particular about tax planning on, therefore writer can glean from that firm has applied effective so corporate tax planning can't economize taxes charges payment it. To economize taxes, expedition company ought to applies tax planning, which is with shift cost that don't be admitted fiskus as accrued expenses fiskus as deducted as productions. In shifts cost, firm shall regard impact of that cost shift. Meanwhile to avoid of corporate maximum tax rate gets to broadcast production as production of some taxpayer, which is with make proprietary branch office as new firm that includes in group firm, then broadcasts proprietary production corporate to that new firm. With that implement, firm can economize taxes who shall be paid to state, and that thrift gets to be utilized to do marketing region extension and for things what do get to increase quality and firm amount.

scholarly journals Personal Income Taxation in Poland

Ekonomika ◽  
2008 ◽  
Vol 84 ◽  
Author(s):  
Edyta Małecka-Zieńska
Keyword(s):  
Income Tax ◽  
Value Added ◽  
Personal Income ◽  
Tax Rates ◽  
Personal Income Tax ◽  
Tax Rate ◽  
Tax Exemptions ◽  
Tax Deductions ◽  
The One ◽  
Taxation System

The Polish taxation system has been undergoing substantial changes in recent years, aimed at creating a more transparent system and conforming to the taxation standards of market economy countries. The two most important changes were introduction of the personal income tax (PIT) in 1992 and replacement of the turnover tax with the value added tax (VAT) in 1993. The uniform personal income tax covered all incomes generated by natural persons irrespective of where the sources of income are located. The reform provided also a more equitable distribution of the tax burden by introducing a progressive system with three nominal tax rates (in 1992-20%, 30%, 40%).A comparative study of the effective PIT rate for pensioners and other groups of PIT payers is the main goal of this paper. The study refers to our own research on data received from The information of Polish Ministry of Finance about accounting of PIT in several subsequent years. Statistics cover a period from 1993 to 2003. However, numbers of taxpayers refer also to year 1992 when the PIT has been established and a period from 2004 to 2006.Concluding the situation in Poland, taxpayers with the highest income make exhaustive use of tax reductions. There are occurring situations when well-off people benefit more than people with relatively minor income (e. g. pensioners). It happens even if most of deductions were aimed generally at all taxpayers. Such a situation reduces the impression of the system fairness. Because tax deductions reduce budgetary revenues, the foregone revenues have to be compensated by other taxes or / and higher rates. Therefore, the system of deductions and relief, on the one hand, supports the special gains (e. g. house building), however, on the other it generates costs. It is possible that the reduction of tax rate for the I tax bracket and removal of some tax exemptions and deductions would make the Polish personal income tax more transparent, equal and simple.

scholarly journals A Study from Slovakia on the Transfer of Slovak Companies to Tax Havens and Their Impact on the Sustainability of the Status of a Business Entity

2019 ◽  
Vol 11 (10) ◽  
pp. 2803
Author(s):  
Samer Khouri ◽  
Lubos Elexa ◽  
Michal Istok ◽  
Andrea Rosova
Keyword(s):  
Income Tax ◽  
Financial Statements ◽  
Tax Planning ◽  
Corporate Income Tax ◽  
Profit Shifting ◽  
Tax Havens ◽  
Tax Haven ◽  
Before And After ◽  
The Status ◽  
The One

The main aim of this paper is to provide empirical evidence about profit-shifting to selected tax havens by Slovak companies. This contribution focused on the very rare evidence of use of tax havens by Slovak companies not only in the field of corporate income tax, but also in selected areas of profitability. Two sources of data were used. Lists of Slovak companies with tax haven links were provided by the company, Bisnode, and financial statements of investigated companies were gained from the Finstat database. Based on the available data, the investigated period was between 2008 and 2016. We statistically tested selected indicators (ETR, taxes per assets, ROE, ROA, and ROS) of Slovak companies with direct ownership links to tax havens compared to their counterparts. Our findings suggest that Slovak companies with an ownership link to tax havens pay significantly lower taxes compared to companies without ownership links to tax havens during the period monitored. The aggressive tax planning was not only confirmed by the significantly lower reported values of ETR and taxes per assets, but also by the lower values of ROA. On the one side, Slovak companies with ownership links to midshore tax havens had the highest values of ROE, ROA, and ROS, but on the other side, these Slovak companies reported the highest ETR among the appointed categories (onshore, midshore, and offshore). The lowest taxes paid per unit of total assets were found in Slovak companies with ownership links to onshore tax havens. The analysis was supplemented by the changes of the selected indicators before and after obtaining an ownership link to a tax haven.

The Liability of Life Assurance Companies to pay Income Tax upon Income arising from Investments in Foreign Countries

1903 ◽  
Vol 37 (4) ◽  
pp. 402-436
Keyword(s):  
Great Britain ◽  
Income Tax ◽  
Life Assurance ◽  
Foreign Countries

The point in this case was whether the Society was liable to be assessed in respect of interest, dividends, and rents, arising from investments in foreign countries.The Society had large funds invested in various forms in foreign countries, in some of which countries the Society carried on the business of Life Assurance, and in others of which it carried on no business of any kind. It was admitted that only a part of the income arising from these investments was remitted to Great Britain, the rest of such income being either reinvested or remitted direct to other foreign countries for investment, or applied in payment of establishment and other expenses in the country where the interest was earned, or remitted direct to other foreign countries for the general purposes of the Society.

scholarly journals KEUNTUNGAN DAN KERUGIAN PENGGUNAAN METODE GROSS-UP DALAM PERHITUNGAN PPh PASAL 21 PEGAWAI TETAP MELALUI ANALISA PERBANDINGAN

2019 ◽  
Vol 1 (1) ◽  
pp. 10
Author(s):  
Andri Marfiana
Keyword(s):  
Income Tax ◽  
Tax Planning ◽  
Optimal Result ◽  
Tax Rate ◽  
Research Questions ◽  
Planning Action

This research aims to show a comparative between Gross-Up method with others method to calculate article 21 income tax in order to tax planning action. Moreover, this journal gives a tutorial, how to calculate Article 21 Income Tax, use Gross-Up method in Ms Excel and e-SPT aplication. This research uses descriptive and tutorial method to discuss research questions. The result shows that the implementation of Gross-Up method in calculating article 21 income tax, only gives optimal result if implemented to employees who has salary below company tax rate. Contrary,  the result will be minumum if used to employees who have higher tax rate. However, income tax benefit that give to employees can increase a motivation among them.In this study, it is argued that the implementation of Gross-Up method can be optimal in situational cases.

scholarly journals Analisa Perhitungan PPh 21 dengan Menggunakan Metode Gross Up di CV. MUSTIKA Mojokerto

2017 ◽  
Vol 1 (1) ◽  
pp. 45-56
Author(s):  
Ahfi Nova Ashriana
Keyword(s):  
Income Tax ◽  
Logical Consequence ◽  
Tax Planning ◽  
Net Income ◽  
Corporate Tax ◽  
Tax Rate ◽  
Tax Allowance ◽  
Corporate Profits ◽  
Past Conditions

The Gross Up method is a way of calculating income tax by batching net income after tax to get DPP, then after DPP is obtained newly multiplied by tax rate. This method can be used for alternative calculation of Income Tax Article 21 in relation to income tax saving efforts. The purpose of this study is to find out how the treatment of income tax article 21 on the salary of company employees and to know sebesapa big differences in the amount of corporate tax between Gross Up method with non Gross Up.  This type of research is a case study that is a detailed study of a certain obek over a period of time with sufficient depth and thorough including ngkungan and past conditions. The variables in this study is the method of calculating income tax article 21 which includes paid company, paid employer, paid company by using Gross Up.  The result of research shows that (1) Gross Up method can help the implementation of tax planning, because by using this method the company's operational expenses increase that is the burden of allowance PPh 21 which is charged to the company. So that corporate profits can be minimized. (2) Tax planning using Gross Up method is a concept to improve the efficiency of calculation of PPh 21 which is deducted by the employer and can determine the amount of tax allowance paid by the employer. (3) In this way the company will benefit on a fiscal basis because the income tax benefit of PPh 21 may be a deduction from the taxable income of the employer (the company). The logical consequence of this method is the amount of tax payable 21 which will be paid by the company will be big due to the added element of tax allowance in the procedure of calculation of income tax 21 employees

scholarly journals ANALISIS PENGARUH KEPEMILIKAN INSTITUSI, RASIO TOBIN Q, AKRUAL PILIHAN, TARIF EFEKTIF PAJAK, DAN BIAYA PAJAK DITUNDA TERHADAP PENGHINDARAN PAJAK PADA PERUSAHAAN PUBLIK

2019 ◽  
Vol 4 (2) ◽  
pp. 113
Author(s):  
Hotman T Pohan
Keyword(s):  
Tax Evasion ◽  
Income Tax ◽  
Tax Avoidance ◽  
Institutional Ownership ◽  
Tax Planning ◽  
Income Smoothing ◽  
Earning Management ◽  
Generally Accepted Accounting Principles ◽  
Tax Rate ◽  
Deferred Tax

<p><em>The effort of tax planning by management or owner of corporate to decreas pay off tax obligation of corporation.Tax avoidance is part of tax planning wihtout conflict with tax rule,meanwhile tax evasion is tax planning that to conflict with tax rule .There are two kind of income for tax,first is income before tax which its calculation base on generally accepted accounting principles,second is income tax which calculation base on rule of statutory,however income tax can not be known directly therefore was is need estimated number for its proxy. The different kind of income is namely book-tax differrent(BTD),its proxy for tax avoidance. The objective of this research is to prove the factors that assumed influence book -tax different significantly or not. The methodology of this research is multivariate analysis with independent variables which are institutional ownership, Tobin Q, income smoothing, discreanary accrual proxy for earning management, efective tax rate, and deferred tax expense.The result of this research, is to prove that earning management influence negatively and significantly toward book-tax difference, income smoothing influence positively and significantly, efective tax rate influence positive and significantly toward boo-tax difference ,meanwhile institutional ownership and deferred tax expense has no influence toward book-tax difference,simultaniosly all factors significantly influence toward book-tax different with coefficient determination 26,5%.</em></p>

Pembaharuan Pesantren: Arah dan Implikasi

2018 ◽  
Vol 4 (1) ◽  
pp. 67-84
Author(s):  
Wahyudin Noor
Keyword(s):  
Rapid Development ◽  
The Other ◽  
Learning Methods ◽  
Technology Learning ◽  
Other Hand ◽  
The One ◽  
Traditional Term

Abstract Pesantren are often associated with backwardness and traditionalism in everything: facilities, technology, learning methods, and even the curriculum. For now, it seems like the traditional term for pesantren is no longer relevant enough. The pace of movement in the era of renewal marked by the rapid development of technology has demanded pesantren to make adjustments. However, on the one hand, when viewed from the direction of change, the reform efforts pursued by pesantren are not to erase the old tradition, but merely to add something new so that the old tradition and conditions can be maintained while accepting the presence of a new one. On the other hand, the reform efforts undertaken by pesantren have implications for the fact that the typical values of the pesantren are fading away. Abstrak  Pesantren seringkali diasosiasikan dengan keterbelakangan dan tradisional dalam segala hal: fasilitas, teknologi, metode pembelajaran, dan bahkan kurikulumnya. Untuk saat ini, sepertinya istilah tradisional untuk pesantren, sudah tidak lagi cukup relevan. Laju gerak pembaharuan zaman yang ditandai dengan pesatnya perkembangan teknologi telah menuntut pesantren untuk melakukan penyesuaian diri. Kendatipun demikian, di satu sisi, jika dilihat dari arah perubahan, upaya pembaharuan yang ditempuh pesantren tidaklah untuk menghapus tradisi yang lama, tetapi sekadar menambah dengan sesuatu yang baru sehingga tradisi maupun kondisi yang lama bisa dipertahankan sambil menerima kehadiran yang baru. Di sisi yang lain, upaya pembaharuan yang dilakukan pesantren ternyata berimplikasi pada kenyataan akan semakin pudarnya nilai-nilai khas yang dimiliki oleh pesantren.

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