The Resource Imputation to a foreign corporation of the activities of its employee, agent or independent contractor in host country

Imputation to a foreign corporation of the activities of its employee, agent or independent contractor in host country

Label
Imputation to a foreign corporation of the activities of its employee, agent or independent contractor in host country
Title
Imputation to a foreign corporation of the activities of its employee, agent or independent contractor in host country
Creator
Subject
Language
eng
Summary
Facts: FC, a foreign corporation for Host Country income tax purposes, is engaged in a trade or business outside of Host Country and currently has no contacts with Host Country. In order to expand its business, FC is contemplating: 1. sending an employee (E) to Host Country; 2. engaging an agent (A) that operates in Host Country; or 3. engaging an independent contractor (other than an agent) (IC) that operates in Host Country. With respect to IC, IC would be either a contract manufacturer (CM) manufacturing product for FC and then shipping it to customers in Host Country pursuant to FC's instructions, or a distributor (D) importing product from FC and then selling it to D's own customers in Host Country. Questions: A. Under what circumstances would the activities of E, A or IC in Host Country subject FC to income taxation in Host Country under its internal law? With respect to E, might E be subject to taxation in Host Country but not FC or FC subject to taxation but not E? With respect to A, what difference would it make whether A was a dependent agent (DA) or an independent agent (IA), and how are those terms understood for purposes of Host Country's income tax law? B. How might the answers in section A. be affected if a Host Country income tax treaty applied?
Citation source
In: Tax management international forum. - London. - Vol. 29 (2008),
http://library.link/vocab/creatorName
Messineo, A.E.
Language note
English
http://library.link/vocab/subjectName
  • foreign company
  • agent
  • contractor
  • contract manufacturing
  • tax treaty
Label
Imputation to a foreign corporation of the activities of its employee, agent or independent contractor in host country
Instantiates
Publication
Contents
Argentina p. 3-7; Belgium p. 7-9; China p. 10-12; Denmark p. 13-14; France p. 15-17; Germany p. 18-20; India p. 21-23; Italy p. 23-25; Japan p. 26-29; Netherlands p. 30-33; Spain p. 34-38; Switzerland p. 39-41; United Kingdom p. 42-45; United States p. 46-51
Label
Imputation to a foreign corporation of the activities of its employee, agent or independent contractor in host country
Publication
Contents
Argentina p. 3-7; Belgium p. 7-9; China p. 10-12; Denmark p. 13-14; France p. 15-17; Germany p. 18-20; India p. 21-23; Italy p. 23-25; Japan p. 26-29; Netherlands p. 30-33; Spain p. 34-38; Switzerland p. 39-41; United Kingdom p. 42-45; United States p. 46-51

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