International-Taxation国际税收-试卷5.doc
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1、Four short words sum up what has lifted most successful individuals above the crowd: a little bit more.-author-dateInternational-Taxation国际税收-试卷5上 海 金 融 学 院 试 题 四 I. True or false (10 marks, 2marks/each)1. The transfer price is a price lower than the market price.( )2. Generally, many countries use
2、the domicile criterion to identify the residence of legal entity. ( )3. Many countries adopt the incorporation criterion to decide the source of business income.4.Every tax treaty may involve two or more contracting states.( )5.Tax sparing policy may benenfit more developing countries than developed
3、 countries. ( )Please explain the following key terms. (12 marks,3 marks for each key term )1. profit-split method 2. tax sparing3. International double taxation 4. Advance pricing agreement. Questions ( 28 marks )1. Please explain what methods may be used by resident country to eliminate the intern
4、ational double taxation caused by the conflicts between the residence jurisdiction and source jurisdiction. Compare these methods and explain further which method are the best method .(8 marks)2. Please explain the difference between the direct crdit and indirect credit. (4 marks) 3. Please explain
5、what methods may be used by multinational individual taxpayers to have a international tax avoidance.(6 marks) 4. What factors may cause the international tax avoidance?(3marks)5. What charactors may tax heaven countries have? (7 marks). Case Study ( 20 marks )一 A Dutch limited company provided oil
6、to two locations in Germany through underground pipes laid between two countries. All the pipes were owned by the Dutch company, and the oil transportation was controlled remotely by the computer in Netherlands. The company didnt send personnel to Germany, and all the technology and marketing staff
7、were in Netherlands. The pipes laid in Germany were maintained and repaired by some independent contractor. Think about that whether the pipes can be regarded as PE? Why?二 A Japanese individual resident was employed in Beijing Taihua Company from March 1 2002 to Oct. 1 2002. He got dependent service
8、 income since he provided technology services to the above company. Question: In which cases the Beijing tax bureau could levy income tax on this person?V. Computation ( 30 marks)一 There is a resident company E situated in State A. Its gross income is $200,000, including $120,000 earned from State A
9、, and $80,000 from State B in some taxable year. E pays a foreign income tax of $32,000 (the income tax rate in State B is 40% and its income tax rate in State A is 45%).calculate seperately how much income tax E shoule pay without any relief methods and with deduction method. 二 There is a resident
10、company F situated in State A. Its gross income is $200,000, including $120,000 earned from State A, and $80,000 from State B in some taxable year. F pays a foreign income tax of $32,000 (the income tax rate in State B is 40%). As income tax rate is 45%, but it provides 10% income tax for its reside
11、nts foreign-source income. calculate seperately how much income tax E shoule pay without any relief methods and with low-tax-rate method. 答案及评分标准 I.True and False ( 10marks, 2points/each): Please explain the following key terms. (12 marks,3 marks for each key term )1. profit split method: a method f
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