Prior to 2012, the Chinese VAT applied primarily to supplies of goods, with supplies of services, including financial services, subject to a turnover tax known as the Business Tax. The value of financial services in respect of a loan was interpreted as the gross interest payable on the loan. As...

While income splitting for tax purposes is not generally allowed in the Canadian income tax system, the tax law does allow persons making support payments to transfer liability for tax on the payments to the recipient of the payments. The Canadian rule was copied from U.S. precedent even though...

Under the China-UK double tax agreement, UK firms deriving profits in China are protected from Chinese tax liability on the profits unless the profits are derived through a permanent establishment. Unlike the original 1984 treaty between China and the UK, the current treaty, effective from 1...

Australian income tax law provides taxpayers making donations to charities with a deduction for the amount of the donations. It also provides public benevolent institutions with an exemption from income taxation for income derived by way of gift or from the investment of donated funds. The...

The issues raised by VAT and financial investments may be the most challenging of all VAT and financial supplies to resolve. In a model VAT, there would be full recovery of all VAT associated with savings and investment. Three problems make it difficult to achieve this aim in respect of...

The modern value added tax is a comprehensive tax with rules for all supplies of goods and services. This paper provides a VAT design guide for designers of a reformed VAT law in China. It explains the theory and practice of VAT and explores all the issues that must be considered in the design...

The proliferation of exempt supplies in VAT systems, particularly the traditional European VAT, undermines the integrity of the tax in many respects. Exempt supplies bear a tax burden equal to the input tax imposed along the supply chain up to the exempt supply. This leads to overtaxation of...

While primary attention on the effect of international agreements on the allocation of taxing rights is on bilateral double tax conventions, a host of non-tax treaties also contain taxation measures. These include both multilateral and bilateral agreements, a large number of which are associated...

In this article, the authors examine a European Commission ruling that classified the U.K. controlled foreign corporation group financing exemptions as illegal state aid and has now been upheld by the General Court of the European Union. They argue that unlike the commission’s previous state...