What are all these “double taxation agreements” or “tax treaties” that we see all the time in Maurice Leaks? SAFE HARBOUR — When tax authorities provide general guidance on the interpretation of tax legislation, they may indicate that transactions in a given area are accepted by the tax authorities without further question. SALE AND LEASEBACK — In a sale and leasing transaction, the owner of the property will sell it to a buyer who will then lease it back to the original owner. This method is sometimes used to free up the value of investments for use in a business. SALES TAX — Tax collected as a percentage of the price of goods (and sometimes services). The tax is usually paid by the buyer, but the seller is responsible for collecting and transferring the tax to the tax authorities. SALVAGE VALUE – The value of a tangible depreciable property when it leaves the service. SCHEDULAR TAX SYSTEM — The tax system in which income from different sources is taxed separately (i.e. on a different “schedule”); As a result, separate tax decisions are made for industrial and commercial profits, wages, income from securities and shares, income from the country, etc. S CORPORATION — See: Small ENTREPRISES SECONDARY ADJUSTMENT — An adjustment resulting from the collection of taxes on a secondary transaction. TWO TRANSACTION — A constructive transaction that some countries will implement in accordance with their national legislation after proposing a primary adjustment to reconcile the effective allocation of profits with the primary adjustment. Secondary transactions can take the form of constructive dividends, constructive equity contributions or constructive loans. SECOND-TIER SUBSIDIARY — A taxable unit controlled by another reporting entity, itself controlled by a third unit. COMPARABLE SECRET – A term used in the context of transfer pricing.
It is an equivalent whose data is not made available to the public or the subject, but is only known to the tax authorities that adjust transfer prices. Section 482 — The portion of the U.S. Income Tax Code that gives the IRS the power to adjust the distribution, splitting or allocation of gross income, deductions, credits or certificates to prevent tax evasion or clearly reflect income (often between controlled taxpayers); In short, the transfer pricing rule in the United States. SECTION 482 WHITE PAPER — A study of intercompany price transactions conducted by the Office of International Tax Counsel at the U.S. Treasury Department, which introduced a new method for regulating transactions related to the sale, licensing or transfer of intangible real estate, published in 1988. SECURITIES documents that represent a share of a company`s capital (for example. B share certificate) or a person`s debt (e.g.B.