Nende hulka kuuluvad kvalifitseeruvate välispankade, offshore-fondide ja ülemaailmsete kaubandusettevõtete pausid. Income derived by a resident of a Contracting State from immovable property including income from agriculture or forestry situated in the other Contracting State may be taxed in that other State. Article 2. Where a Contracting State includes in the profits of an enterprise of that State — and taxes accordingly — profits on which an enterprise of the other Contracting State has been charged to tax in that other State and where the competent authority of the other Contracting State agrees that all or part of the profits so included are profits which would have accrued to the enterprise of the first-mentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State shall make an appropriate adjustment to the amount of the tax charged therein on those profits.
Persons Covered This Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2.
- Мгновение позже его экипаж стремглав промчался мимо нескольких рядов цилиндров, недвижно парившим над своими направляющими.
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Taxes Covered 1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its local authorities, irrespective of the manner in which they are levied.
Juhised maksudeklaratsiooni vormi TSD lisa 7 täitmiseks kuni 31.12.2010
There shall be regarded as taxes on income all Aktsiate maksustamine Singapuris imposed on total income or on elements of income, including taxes on gains from the alienation of movable or immovable property.
The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes.
Tasutav tulumaks: rida 9 — rida 10 — rida — rida 11 — rida — rida 12 — rida 13 positiivne tulem 1 Likvideerimisjaotis 5 krooni koosneb väljamaksmisele kuuluvast summast 3 krooni ja tasumisele kuuluvast tulumaksust 1 krooni.
The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.
Article 3. General Definitions 1.
As regards the application of the Agreement at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time under the law of that State for the purposes of the taxes to which the Agreement applies, any meaning under the applicable tax laws of that State prevailing over a meaning given to the term under other Aktsiate maksustamine Singapuris of that State.
Article 4. Resident 1. Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavour to settle the question by mutual agreement and determine the mode of application of the Agreement to such person.
In the absence of such agreement, such person shall not be considered to be a resident of either Contracting State for the purposes of enjoying benefits under the Agreement. Article 5.
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Permanent Establishment 1. A building site, a construction, assembly or installation project or supervisory or consultancy activity connected therewith constitutes a permanent establishment only if such site, project or activity lasts for a period of more than nine months.
Ülevaade Singapuri raamatupidamisfirmadest
Notwithstanding the provisions of paragraphs 1 and 2, where a person — other than an agent of an independent status to whom paragraph 6 applies — is acting on behalf of an Exxon Mobiil Share Option Tehingud and has, and habitually exercises, in a Contracting State an authority to conclude contracts in the name of the enterprise, that enterprise shall Aktsiate maksustamine Singapuris deemed to have a permanent establishment in that State in respect of any activities which that person undertakes for the enterprise, unless the activities of such person are limited to those mentioned in paragraph 4 which, if exercised through a fixed place of business, would not make this fixed place of business a permanent establishment under the provisions of that paragraph.
An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business. However, if the activities of such an agent are devoted wholly or almost wholly on behalf of that Aktsiate maksustamine Singapuris and the conditions between the agent and the enterprise differ from those which would be made between independent persons, such agent shall not be considered an agent of an independent status within the meaning of this paragraph.
In such case the provisions of paragraph 5 shall apply.
Järelevalve Singapuris Singapuri madalad maksud ja muud stiimulid välisinvestoritele kvalifitseerivad seda maksuparadiisiks. Alates Üldiselt ei maksusta see kapitali kasvu. Selline maksupoliitika ja asukoht, mis muudab selle väravaks ettevõtetele, kes loodavad laieneda Aasia arenevatesse majandustesse, on teinud sellest saarelinnast rahvusvahelise investeeringute ja kaubanduse ülemaailmse sõlmpunkti. Võtmed kaasa Väikest Aasia riiki Singapuri on kiidetud kui rahvusvahelise kaubanduse ja rahanduse keskust.
The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State whether through a permanent establishment or otherwiseshall not of itself constitute either company a permanent establishment of the other. Article 6.
Income from Immovable Property 1. Income derived by a resident of a Contracting State from immovable property including income from agriculture or forestry situated in the other Contracting State may be taxed in that other State.
The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, any option or similar right to acquire immovable property, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources.
Ships and aircraft Aktsiate maksustamine Singapuris not be regarded as immovable property.
The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property. Where the ownership of shares or other corporate rights in a company entitles the owner of such shares or corporate rights to the enjoyment of immovable property held by the company, the income from the direct use, letting, or use in any other form of such right to enjoyment may be taxed in the Contracting State in which the immovable property is situated.
The provisions of paragraphs 1, 3 and 4 shall also apply to the income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services. Article 7.
Mis tahes kapitali juurdekasvu maksud tasuvad mitteresidendid, kes müüvad aktsiaid Kanadas?
Business Profits 1. The business profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.
If the enterprise carries on business as aforesaid, the business profits of the enterprise may be Kusimused tuleb kusida kauplejatele in the other State but only so much of them as is attributable to that permanent establishment. Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and Aktsiate maksustamine Singapuris enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment.
In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment, including executive and general administrative expenses Alfa Rotary Trading System incurred, whether in the State in which the permanent establishment is situated or elsewhere. Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by Aktsiate maksustamine Singapuris an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article.
No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.
Что это ты теперь задумал. Олвин улыбнулся: -- Так я и знал, что ты что-нибудь да заподозришь.
For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
Where profits include items of income which are dealt with separately in other Articles of this Agreement, then the provisions of those Articles shall not be affected by the provisions of this Article. Nothing in this Article shall prevent a Contracting State from applying its law relating to the taxation of any person who carries on the business of insurance as long as that law is in effect on the date of signature of this Agreement and has not been changed otherwise than in minor respects so as not to affect its general character.