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Tax Treaty Between
Indonesia
and
Vietnam
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Download:
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Not Available
(opens in new window) |
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File Type:
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Status:
In Force
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Number of
Indonesia
Treaties:
40
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See All
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Number of
Vietnam
Treaties:
36
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See All
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Introductory note on Tax Treaty Planning
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Tax Treaties (double taxation agreements or DTAs) are international agreements or
conventions concluded with the object of eliminating double taxation by the contracting
states. To succeed in international tax planning, it is essential to engage in deep
and far-reaching calculations. Tax treaties themselves and the OECD Commentary on
the Model Convention give you practical hands-on guidance on international tax planning
issues.
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Treaty Shopping under the
Indonesia
–
Vietnam
Tax Treaty
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Treaty shopping is the use of a tax treaty by a person resident in a country that
is not a party to the treaty, i.e. in the present instance by someone who is a resident
of neither
Indonesia
nor
Vietnam. However, it is becoming
more and more difficult to use provisions, which were intended to prevent double
taxation, in such a way that they result, for the purposes of an international tax
plan.
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Tax Treaty news from the OECD
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The OECD has released two reports submitted to its Committee on Fiscal Affairs by
an Informal Consultative Group of business and government representatives. The Reports
address, respectively:
(a) Technical issues relating to granting treaty benefits with respect to income
of collective investment vehicles; and
(b) Procedural barriers to claims for treaty benefits that affect portfolio investors
more generally.
These are issues which may impact on international tax planning transactions.
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Know your Offshore Terms:
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| | The activities that can be carried out by coordination centers generally fall into two principal categories: (a) support services rendered directly to other members of the group; and (b) financial services provided indirectly through inter-company transactions. To qualify for coordination center status, the center must form part of an international group of affiliated companies with a very substantial aggregate capital and annual turnover. A coordination center may find a useful place in an international tax plan. | | | | | A method employed for transfer pricing purposes in order to determine the price that is charged by similar companies selling the same or similar products in the same or similar circumstances. | | | | | The Internet is the greatest advance in the communication of information since the telephone and the fax machine. Never before has so much information been so readily available to so many people. However, like any other research tool, the Internet has its strengths and its weaknesses. Even Government and Revenue websites need to be watched for accuracy and for how current they actually are. This inevitably creates problems for the international tax planner seeking information both where onshore jurisdictions and tax havens or international offshore financial centers (IOFCs) are concerned | | | | | Headquarters offices may be defined as offices that belong to an enterprise or an international group of enterprises, that are situated abroad, and that exercise certain management, co-ordination, and control functions for the sole or principal benefit of the enterprise or group. Headquarters offices may benefit from a favourable tax regime even in an otherwise high tax jurisdiction, thus enabling them to function as if they are in a tax haven or an international offshore financial center (IOFC). Operational headquarters providing management, technical, or other supporting services to subsidiaries and/or associated companies in other countries may also benefit from favored tax treatment, thus favoring the international tax plan. | | |
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