корпоративный английский язык
Корпоративный английский язык
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corporate taxcorporation taxcompany tax
- corporations incorporated in the country,
- corporations doing business in the country on income from that country,
- foreign corporations who have a permanent establishment in the country, or
- corporations deemed to be resident for tax purposes in the country.
Company income subject to tax is often determined much like taxable income for individuals. Generally, the tax is imposed on net profits. In some jurisdictions, rules for taxing companies may differ significantly from rules for taxing individuals. Certain corporate acts, like reorganizations, may not be taxed. Some types of entities may be exempt from tax.
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Most countries exempt certain types of corporate events or transactions from income tax, for example events related to formation or reorganization of the corporation, which are treated as capital costs. In addition, most systems provide specific rules for taxation of the entity and/or its members upon winding up or dissolution of the entity.
Some systems provide a mechanism whereby groups of related corporations may obtain benefit from losses, credits, or other items of all members within the group. Mechanisms include combined or consolidated returns as well as group relief (direct benefit from items of another member).
Many systems (particularly sub-country level systems) impose a tax on particular corporate attributes. Such non-income taxes may be based on capital stock issued or authorized (either by number of shares or value), total equity, net capital, or other measures unique to corporations.
U.S. Corporation defined
Examples of corporate tax rates for a few English-speaking countries include:
- Australia: 28.5%, however some specialized entities are taxed at lower rates.
- Canada: Federal 11%, or Federal 15% plus provincial 1% to 16%. Note: the rates are additive.
- Hong Kong: 16.5%
- Ireland: 12.5% on trading (business) income, and 25% on non-trading income.
- New Zealand: 28%
- Singapore: 17% from 2010, however a partial exemption scheme may apply to new companies.
- United Kingdom: 20% to 21% for 2014–2015.
- United Kingdom: 20% for 2016
- United States: Federal 15% to 35%. States: 0% to 10%, deductible in computing Federal taxable income. Some cities: up to 9%, deductible in computing Federal taxable income. The Federal Alternative Minimum Tax of 20% is imposed on regular taxable income with adjustments.
Distribution of earnings
The following illustrates the dual level of tax concept:
C Corp earns 100 of profits before tax in each of years 1 and 2. It distributes all the earnings in year 3, when it has no profits. Jim owns all of C Corp. The tax rate in the residence jurisdiction of Jim and C Corp is 30%.
|Year 1||Cumulative||Pre-tax income||Taxes|
|Net after tax||70|
|Jim's income & tax||0|
|Net after tax||70|
|Jim's income & tax||0|
|Net after Jim's tax||98|
Other corporate events
Many systems provide that certain corporate events are not taxable to corporations or shareholders. Significant restrictions and special rules often apply. The rules related to such transactions are often quite complex.
Interest deduction limitations
A common form of limitation is to limit the deduction for interest paid to related parties to interest charged at arm's length rates on debt not exceeding a certain portion of the equity of the paying corporation. For example, interest paid on related party debt in excess of three times equity may not be deductible in computing taxable income.
Foreign corporation branches
Groups of companies
In addition, a few systems provide a tax exemption for dividend income received by corporations. The Netherlands system provides a “participation exception” to taxation for corporations owning more than 25% of the dividend paying corporation.
A key issue in corporate tax is the setting of prices charged by related parties for goods, services or the use of property. Many jurisdictions have guidelines on transfer pricing which allow tax authorities to adjust transfer prices used. Such adjustments may apply in both an international and a domestic context.
Taxation of shareholders
Alternative tax bases
Many jurisdictions incorporate some sort of alternative tax computation. These computations may be based on assets, capital, wages, or some alternative measure of taxable income. Often the alternative tax functions as a minimum tax.
International corporate tax rates
Corporate tax rates vary widely by country, leading some corporations to shield earnings within offshore subsidiaries or to redomicile within countries with lower tax rates.
|Country||2015 Corporate tax rate|
|Czech Republic||19 %|
|South Korea||22 %|
|New Zealand||28 %|
|Slovak Republic||22 %|
|United Kingdom||20 %|
|United States||35 %|
The corporate tax rates in other jurisdictions include:
|Country||2015 Corporate tax rate|
|Japan||32.11%, with plans to reduce|
|Singapore||17%, with significant exemptions for resident companies|
- Corporate tax rates in Canada
- Corporate tax in the United States
- United Kingdom corporation tax
- List of Tax rates of Europe
- List of Tax rates around the world
- Bittker, Boris I. and Eustice, James S.: Federal Income Taxation of Corporations and Shareholders: paperback ISBN 978-0-7913-4101-8, subscription service
- Kahn & Lehman. Corporate Income Taxation
- Healy, John C. and Schadewald, Michael S.: Multistate Corporate Tax Course 2010, CCH, ISBN 978-0-8080-2173-5 (also available as a multi-volume guide, ISBN 978-0-8080-2015-8)
- Hoffman, et al.: Corporations, Partnerships, Estates and Trusts, ISBN 978-0-324-66021-0
- Momburn, et al.: Mastering Corporate Tax, Carolina Academic Press, ISBN 978-1-59460-368-6
- Norton, Bob (2008). "Corporate Taxation". In David R. Henderson (ed.). Concise Encyclopedia of Economics (2nd ed.). Indianapolis: Library of Economics and Liberty. ISBN 978-0865976658. OCLC 237794267.
- Tolley's Corporation Tax, 2007-2008 ISBN 978-0-7545-3273-6
- Watterson, Juliana M.: Corporation Tax 2009/2010, Bloomsbury Professional, ISBN 978-1-84766-327-6
- CRA main website
- CRA gateway for corporations
- CRA gateway to T2 returns
- HMRC main website
- HMRC Introduction to Corporation Tax
- IRS main website
- IRS gateway for corporations
- IRS Publication 542, Corporations
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