Relevant bibliographies by topics / Tax residency

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  1. Journal articles
  2. Dissertations / Theses
  3. Books
  4. Book chapters
  5. Conference papers
  6. Reports

Academic literature on the topic 'Tax residency'

Author: Grafiati
Published: 4 June 2021
Last updated: 27 April 2022

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Journal articles on the topic "Tax residency"

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Ryabova, Elena V. "Digital Migration of Individuals: Legal Issues of International Taxation." Migration law 2 (June 3, 2021): 26–30. http://dx.doi.org/10.18572/2071-1182-2021-2-26-30.

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Purpose: to assess the existing prospects for e-tax residence on the basis of the revealed significant characteristics of existing approaches to e-individual residence in foreign countries and international tax consequences. Methods: an analysis of the legal regime for e-residents in Estonia from the standpoint of taxing digital business in this country by Russian tax residents, an analysis of the legal regime for digital “nomads” introduced by countries with a comfortable climate, as well as an analysis of a draft introducing e-tax residence regime in Ukraine. The paper is based on the comparative study and the extrapolation of the findings got from the analysis of the draft law in Ukraine to the Russian reality. Findings: the analysis of e-residency regimes for individuals in foreign countries showed the existence of two main approaches to their design: (1) e-residency, not based on physical presence and loss of tax residency in one’s own country, with the right to conduct digital business through a company — tax resident (Estonian experience), and (2) tax residency for digital “nomads” for the purpose of physical presence in a country with comfortable climatic environment and remote work in their countries, accompanied by the potential loss of tax residency in the country of labor or business. Conclusion: In connection with the digitalization, the legislator in foreign countries provides interesting ideas regarding the digital or physical attraction of migrants to their countries. Several countries have announced the launch of e-tax residency programs. However, in the context of traditional international taxation related to personal income such programs will show ineffectiveness.
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Hristov, Dimitar, and Anna Zeitlinger. "Russian tax residency rules and Double Tax Treaties – an Austrian example." Trusts & Trustees 23, no. 6 (July 1, 2017): 627–31. http://dx.doi.org/10.1093/tandt/ttx074.

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Goetz, Eva M. "AURES Holdings a.s. (C-405/18) at the Intersection of Cross-Border Loss Relief, Corporate Exit Taxation and Dual Residency Mismatches." Intertax 49, Issue 2 (February 1, 2021): 166–85. http://dx.doi.org/10.54648/taxi2021015.

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This contribution examines the decision of the Court of Justice of the European Union (CJEU) of 27 February 2020 in Case C-405/18 AURES Holdings a.s. on the application of the Marks & Spencer final losses doctrine to dual resident companies that transfer their treaty residence (place of effective management) to another Member State. The CJEU applied a two-step comparability analysis based on Timac Agro and Bevola to exclude current not-subject-to-tax emigration losses (not linked to the ability-to-pay of the immigrated company) from its preferred approach to always take final losses into account somewhere in the internal market. The immigration state was not forced to apply its taxing powers asymmetrically over emigration losses to prevent a conflict with the principle of fiscal territoriality in exit tax cases and international tax practice against base erosion and profit shifting (BEPS). If the immigration state still sovereignly decides to take these losses into account pursuant to a bilateral tax treaty, Article 9(b) of the Anti-Tax Avoidance Directive (ATAD) on dual residency mismatches prevents dual loss utilization. ATAD, Aures, Bevola, comparability, conversion, exit tax, hybrid mismatch, final losses, POEM, Timac Agro.
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Lincoln, Charles Edward Andrew. "Is Incorporation the Solution to the Enigma of Corporate Tax Residency for International Tax Purposes?" Texas A&M Law Review 7, no. 4 (July 2020): 35–47. http://dx.doi.org/10.37419/lr.v7.arg.3.

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Incorporation of a company for testing residency—if applied uniformly—is likely the best and most accurate way to reflect corporate residency for tax purposes. However, it does not always reflect economic reality. There is not a consensus on what the best approach is. The Organization for Economic Cooperation and Development (“OECD”) countries overwhelmingly use three tests for residency: incorporation, central management and control, and domicile. Indeed, a court in the United States or other jurisdictions may often ask if tax-avoidance motives exist when incorporation occurs in one jurisdiction and central management and control occurs in another. This Article follows the 2017 Tax Cuts and Jobs Act on many international tax provisions that caused a shift in thinking at both the U.S. level, and at the international level in terms of deciding what formulations would be the best way to ensure proper taxation while promoting horizontal and vertical equity. The genesis of this Article is a response and critique of an article on the same subject by the same author: Charles Edward Andrew Lincoln IV, Is Incorporation Really Better Than Central Management and Control for Testing Corporate Residency? An Answer to Corporate Tax Evasion and Inversion, 43 Ohio N.U. L. Rev. 359 (2017). The author now critiques the point of that article and comes to a different conclusion based on different criteria: specifically, new case law, Musgrave’s economic theory of accretion of wealth, and the importance of substance-over-form doctrines.
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Roin, Julie. "Changing Places, Changing Taxes: Exploiting Tax Discontinuities." Theoretical Inquiries in Law 22, no. 1 (January 1, 2021): 335–79. http://dx.doi.org/10.1515/til-2021-0012.

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Abstract President Trump’s decision to move his official state of residence from high-tax New York to no (income)-tax Florida has brought public attention to an issue that has long troubled scholars, designers and administrators of income tax systems: how the interaction of tax rules deferring the taxation of income and tax rules based on residency allows taxpayers to reduce and even avoid taxation of their deferred income. These discontinuities in tax treatment may lead to excessive migration, as well as reductions in state income tax revenues and distortions in the design of state taxing mechanisms. This Article explains what states would have to do to eliminate these avoidance opportunities. However, it also points out that many of these policy changes would create other tax discontinuities. Ultimately, it leaves open the question whether making any of these changes would lead to fewer financial and behavioral distortions.
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Andryushin, Sergey V. "The Essence and Meaning of the “Tax Residency” Category." Financial law 2 (February 19, 2020): 38–41. http://dx.doi.org/10.18572/1813-1220-2020-2-38-41.

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Ware, J., and P. Roper. "South Africa: Brief Overview of the Tax Residency Tests." Trusts & Trustees 8, no. 5 (April 1, 2002): 23–25. http://dx.doi.org/10.1093/tandt/8.5.23.

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Streng, William P. "USA: Revised income tax rules for determining residency status." Intertax 13, Issue 4 (April 1, 1985): 95–96. http://dx.doi.org/10.54648/taxi1985037.

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Cibula, Tomas, Matej Kacaljak, and Peter Rakovsky. "Tax treaties between Slovakia and the Middle East countries." Journal of Research in Emerging Markets 3, no. 1 (January 30, 2021): 58–65. http://dx.doi.org/10.30585/jrems.v3i1.601.

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The objective of this article is to provide a basic systematic review of tax treaties between Slovakia and the Middle East States and their similarities and differences as compared to the standard OECD/UN Model Tax Conventions. The methods used include abstraction, comparison, analysis, synthesis, induction, deduction, and summarization. Findings include diverging practice concerning the scope and objective of double tax treaties such as criteria for residency, zakat provisions, transfer pricing rules, and anti-abuse rules. Taking into account the context of Slovak administrative practice and lack of experience with double tax treaties this diverging practice may lead to occasions of tax treaty override.
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Fathoni, Ahmad, and Sarkawi B. Husain. "Pelaksanaan Opiumpacht: Monopoli Perdagangan Opium Melalui Perantara Bandar di Keresidenan Kediri, 1833-1900." Lembaran Sejarah 16, no. 1 (April 30, 2020): 48. http://dx.doi.org/10.22146/lembaran-sejarah.59912.

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The opium trade in Kediri Residency was monopolized by Dutch East Indies government. The problem discussed in this study regarding opium trade monopoly at Kediri Residency through bookie intermediary (opiumpachter) in 1833-1900. The methods used in this research is historical methods which includes heuristics, criticism, interpretation and historiography. The result showed that the opium trade monopoly through bookie intermediary (opiumpachter) in Kediri Residency included auction and distribution processions also the sale of raw opium to opium dealers. Generally, the opium trade in Kediri Residency was controlled by Chinese. They become intermediary traders who sell government opium to people in Kediri Residency. The high tax offer at opium auction in Kediri Residency gave high profits to the country. On the contrary, that puts a great deal of pressure on the opium port. The crisis which occurred at the end of the 19th century, caused a setback in the opium trade monopoly through bookie intermediary (opiumpachter) in Kediri Residency.
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Dissertations / Theses on the topic "Tax residency"

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Esmenjaud, Juliette. "L'impact de la mobilité internationale sur la fiscalité des personnes physiques." Thesis, Aix-Marseille, 2016. http://www.theses.fr/2016AIXM1027.

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Cette Thèse a pour objet d’identifier les règles qui s’appliquent aux travailleurs mobiles qui s’impatrient en France et ceux qui s’expatrient hors de France et d’en déterminer les conséquences fiscales. Une des problématiques majeures sera celle de la détermination de la résidence fiscale de ces individus mobiles afin d’en déduire les règles qui s’appliquent à eux, tout en tenant compte de la spécificité de chaque situation. Il conviendra de s’intéresser aux mesures et régimes issus de notre droit interne mais aussi à ceux issus du droit conventionnel. En effet, les Conventions fiscales prévoient des règles spécifiques afin que les contribuables ne soit pas imposés plus d’une fois sur les mêmes revenus. Il conviendra de mesurer le champ d’application des règles fiscales particulières prévues pour ces travailleurs dans le contexte de mobilité internationale que nous connaissons
The purpose of this Thesis is to identify the applicable rules for mobile workers, defined as individuals who chose to either move to France for work or become expatriates working abroad, and the tax consequences related to such mobility. One of the main points will be to determine the tax residency of such individuals in order to identify the applicable treatments, by taking into account the specificity of each situation. We will examine the rules and special treatments raised by not only our internal law but by tax treaties as well. Indeed, tax treaties set forth special rules in order to avoid tax payers from being taxed several times on the same income. We will identify the particular tax rules’ field of application that applies for these workers in the context of international mobility
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Stehno, Pavel. "Zdanění příjmů stálých provozoven - problémové okruhy." Master's thesis, Vysoká škola ekonomická v Praze, 2007. http://www.nusl.cz/ntk/nusl-4117.

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Taxation of permanent establishments is one of the most complicated areas within international tax law. The system of permanent establishment is based not only on the national legislations of relevant states, but also (mainly) on the international double taxation treaties. This diploma thesis analyses those issues in the taxation of permanent establishments, which are the most up-to-date or can be considered as the key questions of the whole concept and therefore can be significant for the future development of the permanent establishments. However the technically perfect system of permanent establishments should come hand in hand with the practical feasibility and overall efficiency. This assumption is nowadays challenged by several trends like the growing popularity of offshore tax heavens or the development of information technologies, which complicate the determination of (fixed) place of business through which the business of an enterprise is wholy or partly carried on. The technical analyses in this thesis are, therefore, supplemented by the objective evaluations from the perspective of valid legislation, possible approaches of the tax authorities, as well as of the enterprise considerations and also the global international taxation picture. This involves also the aspects of tax policies at the level of sovereign states, especially the Czech Republic.
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Loomer, Geoffrey T. "Reformulating corporate residence : a coherent response to international tax avoidance." Thesis, University of Oxford, 2011. http://ora.ox.ac.uk/objects/uuid:1f515456-3d87-4942-9600-b9cfe73c6662.

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This thesis analyzes the concept of corporate residence, with particular reference to the law in the UK and Canada. It explores why corporate residence is relevant in tax policy, how corporate residence is understood in law, and how revenue authorities respond to the use and alleged 'abuse' of residence rules. Part I argues that the residence of taxpayers generally (individual or corporate) remains a relevant factor in international tax design, that taxation of corporations on the basis of residence has some justification, but that there is a disjunction between meaningful residence-based taxation and current definitions of corporate residence in domestic law and tax treaties. The formulations of residence based on incorporation, central management and control, and place of effective management, particularly as applied to multinational enterprises, are considered and are found to be deficient. Part II critically analyzes the major policy responses of the UK and Canadian governments to the exploitation of corporate residence. It argues that key legislative and administrative responses to international tax avoidance activities, for both outbound and inbound investment, are purportedly based on the acceptance of formal corporate residence yet undermine that concept in an effort to impose tax or refuse treaty relief based on where economic interests actually exist. The responses considered are the application of controlled foreign companies legislation to offshore subsidiaries, the invocation of treaty anti-abuse rules with respect to offshore intermediaries, and the use of overarching general anti-avoidance measures to challenge varied structures that rely on offshore entities. These haphazard anti-avoidance rules are overlaid with revenue authorities' indignation at the motivations that underlie many corporate relocations. It is argued that a more coherent approach would be to focus on the objective reality or unreality of corporate establishment, by reformulating corporate residence in domestic law and tax treaties.
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Xu, Yiyi. "Property Tax Reform in China : Optional property tax proposals and the effects on residence price." Thesis, KTH, Bygg- och fastighetsekonomi, 2011. http://urn.kb.se/resolve?urn=urn:nbn:se:kth:diva-48595.

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This paper gives some theoretical instructions of China’s property tax reform which include the reform of land lease system, the design of tax base, tax rates and tax relief, and also provides some interesting property tax proposals for Shanghai and estimates the effects of property tax reform on residence price.This paper selects a case study of Shanghai which can provide useful methods or findings to other cases characterized by similar traits and situations. Through observation and analysis of documentary evidence, the new average residence price and the prices of residences which locate around the inner ring road and the outer ring road are estimated. Moreover, this study uses asset pricing theory, partial equilibrium theory and quantitative simulation analysis to explore the impact of property tax reform on the residence price under the combinations of varied property tax rates, discount rates and tax base. The paper also uses comparative analysis in lots of areas. The data is gathering from National Bureau of Statistics, local bureaus of statistics, World Band, several valuation firms, international and local theses.The author provides 4 proposals of Shanghai. After the simulation analysis, the first proposal is seen as the most mildly proposal with low property rates and small tax base. The total residence value decreases about 4.92 percent of the original value after the property tax reform. The second proposal use graduated property tax rates corresponding to different property value, which may have greater fairness and equality but lower efficiency. The third proposal targets at gaining more tax revenue from villa and luxury apartments and adjusts the poverty gap. The sales price after property tax decreases around 10 percent. The fourth proposal provides the idea that property tax rates can be set according to the location of administrative areas. In the future study, a case study of a certain city combined with precise empirical observations and statistics data is a good direction. Moreover, this study only introduces a simple model and some indicators which affect the house price. However, how to narrow down the indicators and to use an effective model and to use property tax as an effective indicator to affect residence price is the next step.
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López, Saldaña Cesar. "Some comments to the tax consequences arising from cross-border secondment of staff." IUS ET VERITAS, 2017. http://repositorio.pucp.edu.pe/index/handle/123456789/122399.

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The objective of this article is to analyze, from a tax perspective some aspects arising from the secondment, such as the possible double residence of the employees assigned, the application of income tax on income from personal servicedependent on light model Convention for the Avoidance of Double Taxation of the Organization for Economic Cooperation and Development (“OECD CDI”) and the possible establishment of a permanent establishment by assigning employees to the State of destination.
El objetivo del presente artículo es analizar, desde un punto de vista tributario, algunos aspectos derivados del secondment, tales como la posible doble residencia de los empleados asignados, la aplicación del Impuesto a la Renta sobre los ingresos derivados del servicio personal dependiente a la luz del Modelo del Convenio para Evitar la Doble Imposición de la Organización para la Cooperación y Desarrollo Económico (“CDI OCDE”) y la posible constitución de un establecimiento permanente por la asignación de empleados al Estado de destino.
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Mabele, Katlego Oliva. "The income tax implications of becoming a republic resident." Thesis, Nelson Mandela Metropolitan University, 2016. http://hdl.handle.net/10948/14521.

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The aim of this treatise is to identify the income tax implications of the persons becoming South African tax residents. It will provide a clear understanding of the income tax implications for natural and non-natural persons wishing to take up residence in South Africa. The definition of “resident” in section 1 of the Income Tax Act, 1962, has a direct impact on the tax implications bearing down on any foreigner planning to reside within the Republic of South Africa, especially in relation to the prevention of the double taxation. The following issues or areas have been identified, these issues are summarised below. The persons receiving foreign pensions may be exempt from normal tax under section 10 (1)(gC) and in terms of the tax treaty, they may also escape taxation in their former country of residence. The treatise will look at various treaties that exist between the South Africa and other countries and to discuss the taxing rights. There is a case of double non-taxation and good reason for immigrants to come and avoid tax in South Africa. It is suggested that the legislation and the double tax agreements should be amended. A person who becomes a resident will receive a step-up in base cost for assets other than South African immovable property and assets of a permanent establishment in South Africa under paragraph 12(2)(a) of the Eighth Schedule. The main purpose of the legislation is to ensure that these assets are correctly valued, determining the base cost, when the person becomes a tax resident. The valuation of these assets carries with it the problem of securing sufficient evidence long after the valuation. Most of the tax planning for such for immigrants revolves around estate duty and donations tax. The person would donate his assets to an offshore discretionary trust before taking up residence in South Africa. The advantage is that donations tax will be avoided because there are exemptions in terms of section 56, for assets acquired before becoming a resident. The income and capital gains vested in nonbeneficiary can be taxed in the hands of the donor in terms of section 7 and paragraph 72 of the Eighth Schedule. The donor should be aware of the antiavoidance measures; section 7(2) to 7(8) and paragraph 72 of the Eighth Schedule will deem a different person other than the person who is entitled to the income to be taxable on that person. The income and gains received by the beneficiary of a trust can be taxable in the hands of the donor. The assets owned by the trust will be sheltered from South African estate duty. The foreign discretionary trust, as a non-resident, will not be liable for tax in South Africa. The beneficiaries of such a trust will be liable for income tax from the trust distributions, once they have acquired a vested right to the income. The liability of income tax is deferred to the year when the trustees decide to make distributions. The distribution by the trustees in a subsequent year creates a delay or postponement for taxes which should be paid by the beneficiaries. The trustees are most likely to make distributions in a tax year when the tax rates are low. There are tax opportunities for the immigrants who intend to take up residence. The tax resident might be subject to withholding taxes on foreign income from the previous country of residence, but might be subject to Double Tax Agreement between South Africa and other countries.
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Mosupye, S. (Sedumedi). "Expatriate tax in Africa : the taxation of inbound Expatriate working in Botswana, Namibia, Nigeria and South Africa." Diss., University of Pretoria, 2013. http://hdl.handle.net/2263/41218.

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The growth in multinational corporations looking to expand and invest in foreign countries, particularly in the emerging markets such as Africa, has grown tremendously. “Africa is already the world’s second fastest growing economy after expanding 5% a year in the past two years, well above the global average.” (World Economic Forum, 2013). This has resulted in the movement of human capital between different tax jurisdictions and an increase in expatriates all across the world. The focus of the study is to expand on the current knowledge on the taxation of inbound expatriates working within South Africa, Botswana, Namibia and Nigeria, as the world has turned its focus on Africa in terms of investment and expansion, as supported by Shelley (2004:3), and to provide both employers and employees with knowledge of the different tax regimes (source-based taxation and residence-based taxation) found in some of the emerging and fastest growing markets in Africa: namely Botswana, Namibia, Nigeria and South Africa. It was found that the African tax landscape provides for a vast range of tax systems, of which, most are either residence–based or source-based. The tax systems of South Africa and Nigeria are similar in that they are residence-based. In each of these two countries, tax residents are taxed on their worldwide income, while non-residents are only taxed on income from specific sources. Therefore, residency is an essential concept in each of these tax systems. The above-mentioned countries, however, apply different methods and factors in determining the concept of residency. As a result of the difference in determining tax residency and differences in their domestic income tax legislations, the taxability of income earned abroad differs in these countries. The tax systems of Botswana and Namibia are similar in that they are source-based. In each of these countries, income is taxable when it is from a source or deemed source within these countries. Although in exceptional circumstances, some income which is not from a source within these countries may be taxable, relief is applied in terms of the domestic legislation, in order to lessen the burden of tax. Source is therefore a vital concept in each of these tax systems. The definition and application of the term source is different in both countries. However, similarities are found in that the source is primarily where the services were physically rendered. Both employers and employees should consider the basis of taxation (source basis and residence basis) that is applied by the prospective host country when making a decision regarding an assignment to a foreign country as this forms a major factor in how their income (both local and foreign) will be treated.
Dissertation (MCom)--University of Pretoria, 2013.
Taxation
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Walker, Anthony Howard. "The South African tax implications of ceasing to be resident." Thesis, Rhodes University, 2017. http://hdl.handle.net/10962/5555.

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In the context of rapid globalisation, skilled South African employees and professionals are often attracted overseas to take up new work opportunities in foreign countries. This may cause these individuals no longer to be “ordinarily resident” in South Africa. At the same time, changes in modes of travel, information and communication channels could result in companies and trusts no longer being considered to be tax resident in South Africa, if the place of effective management for these entities is moved to a foreign country and a double taxation agreement between South Africa and that foreign country deems these entities to be exclusively resident in the foreign country. The objective of this thesis was to analyse the tax implications that could arise when a resident natural person, trust or company ceases to be a resident or when a Controlled Foreign Company (CFC) ceases to be a CFC. A detailed analysis of the “exit charge” in section 9H of the Income Tax Act was undertaken to understand its normal tax implications when a natural person, trust or company ceases to be a resident or a CFC ceases to be a CFC. This included an analysis of how a natural person, trust or company ceases to be resident or how a CFC ceases to be a CFC. It was found that certain normal tax principles consistently apply to when a natural person, trust or company ceases to be resident or a CFC ceases to be a CFC. At the same time, certain unique normal tax implications arise for trusts and CFCs since they are impacted by the special tax rules that apply to these entities. Furthermore in the case of a trust, a judicial precedent has established that the “exit charge” remains and is taxable in the trust. For CFCs, there is uncertainty as to whether the “exit charge” could arise when a shareholder ceases to be resident, which results in residents no longer holding more than 50% of the total participation or voting rights in that foreign company.
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Ujjin, Bundit. "Thai legislative tax jurisdiction over physically absent non-resident sales companies." Thesis, Brunel University, 2006. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.426224.

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Van, der Merwe de Vos Wouter. "Taxation of non-residents in South Africa with specific reference to withholding taxes." Thesis, Nelson Mandela Metropolitan University, 2017. http://hdl.handle.net/10948/21296.

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This treatise tests the effectiveness of withholding taxes imposed by the South African tax authorities with respect to amounts paid from a South African source to a non-resident in respect of interest, royalties and foreign entertainers and sportspersons. The first research objective discusses the alignment of the meaning of words and phrases in both the domestic law of South Africa and Double Tax Agreements (DTA.) The second issue outlines whether the DTA supports the domestic law through the waiving of tax claims in favour of the country of source. In last instance the attribution of income is discussed. The interpretation attached to the words for the purpose of levying normal tax, serves as the methodology for identifying inconsistencies with the levying of withholding tax. The wider scope of withholding taxes with respect to the meaning of ‘interest’, ‘royalties’ as well as ‘foreign entertainer and sportsperson’ misaligns with the corresponding meaning of it in the DTA. This creates the risk that amounts paid to non-residents will either not be subjected to withholding tax in the source state or that the income will be taxable in the resident state as a result of the application of other articles of the DTA. DTA’s concluded between South Africa and other countries are based on the OECD Model Tax Convention. These DTA’s tend to favour the residence state with respect to the waiving of tax claims. The source state’s right to collect withholding tax on income from royalties and interest is prevented if the foreign person is physically present in South Africa for more than 183 days and if the interest/royalty payment is effectively connected with a permanent establishment in South Africa. The domestic law and DTA are misaligned with respect to the attribution of interest and royalty income since the recipient of the income for the purpose of the domestic law is not necessarily the beneficial owner of the debt claim or intellectual property. It can therefore be recommended that South Africa must renegotiate DTA’s to favour taxation in the source state. Withholding tax provisions must also be redrafted to align them with the DTA meaning.
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Books on the topic "Tax residency"

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Boidman, Nathan. The new U.S. residency rules for Canadians: Tax considerations. Don Mills, Ont: CCH Canadian, 1986.

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Boidman, Nathan. The new U.S. residency rules for Canadians: Tax considerations. Don Mills, Ont: CCH Canadian, 1985.

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Hadnum, Lee. Non-resident & offshore tax planning. Kirkcaldy: Taxcafe UK Limited, 2007.

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Hadnum, Lee. Non-resident & offshore tax planning. Kirkcaldy: Taxcafe UK Ltd., 2010.

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Loukota, Walter, and Hans-Jörgen Aigner. Source versus residence in international tax law. Wien: Linde, 2005.

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Tolley's tax planning for private residences. 2nd ed. Croydon: Tolley, 1994.

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Hutton, Matthew. Tolley's tax planning for private residences. Croydon, Surrey: Tolley Pub. Co., 1992.

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Soares, Patrick C. Non-resident trusts. 4th ed. London: Longman, 1993.

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Robert, Venables. Non-resident trusts. 8th ed. London: Key Haven, 2000.

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Reddy, B. G. Strategic marketing analysis of Taj residency, Hyderabad. Oxford: Oxford Brookes University, 1997.

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Book chapters on the topic "Tax residency"

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Murdock, M. Casey. "Your Residence." In TAX INSIGHT, 293–302. Berkeley, CA: Apress, 2013. http://dx.doi.org/10.1007/978-1-4302-6311-1_27.

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Murdock, M. Casey. "Your Residence." In TAX INSIGHT, 293–302. Berkeley, CA: Apress, 2013. http://dx.doi.org/10.1007/978-1-4842-0629-4_27.

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Murdock, M. Casey. "Your Residence." In Tax Insight, 295–304. Berkeley, CA: Apress, 2013. http://dx.doi.org/10.1007/978-1-4302-4738-8_27.

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Phillips, John S. "Resident." In Tax Treaty Networks 1991, 84–120. London: Routledge, 2021. http://dx.doi.org/10.4324/9781315075631-5.

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Sinclair, Walter. "Domicile and residence." In St. James’s Place Tax Guide 2002–2003, 271–79. London: Palgrave Macmillan UK, 2002. http://dx.doi.org/10.1057/9780230287716_17.

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Strban, Grega, and Luka Mišič. "Migrants’ Access to Social Protection in Slovenia." In IMISCOE Research Series, 391–403. Cham: Springer International Publishing, 2020. http://dx.doi.org/10.1007/978-3-030-51241-5_26.

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Abstract The Slovenian welfare system in its main part consists of a contribution-funded, professional social insurance scheme, composed of compulsory insurance branches, which mirror traditional social risks (contingencies) such as unemployment, old-age, sickness, etc., and a subsidiary tax-funded, residence-based social assistance scheme, which is aimed at preventing poverty and social exclusion. In general, all gainfully employed persons in Slovenia (e.g. workers, self-employed persons) enjoy coverage within the social insurance scheme, irrespective of their nationality or residence status. Citizenship and/or (long-term) residence is however required when accessing means-tested social assistance benefits. Migrants’ access to social rights – with the majority of foreign residents originating from ex-Yugoslav countries – is thereby fore and foremost dependent upon the nature of the benefit (means-tested or not) and their economic (in)activity or (long-term) residence.
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Sinclair, Walter. "Non-residents, visitors and immigrants." In St. James’s Place Tax Guide 2002–2003, 292–98. London: Palgrave Macmillan UK, 2002. http://dx.doi.org/10.1057/9780230287716_19.

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Qingwang, GUO, LV Bingyang, and YUE Ximing. "Gap of resident income distribution." In Regulating Effect of Tax on Chinese National Income Distribution, 78–121. Abingdon, Oxon ; New York, NY : Routledge, 2019. | Series: China perspectives: Routledge, 2019. http://dx.doi.org/10.4324/9780429448126-4.

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Qingwang, GUO, LV Bingyang, and YUE Ximing. "Impact of personal income tax on resident income distribution." In Regulating Effect of Tax on Chinese National Income Distribution, 206–23. Abingdon, Oxon ; New York, NY : Routledge, 2019. | Series: China perspectives: Routledge, 2019. http://dx.doi.org/10.4324/9780429448126-8.

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Martinsen, Dorte Sindbjerg. "Migrants’ Access to Social Protection in Denmark." In IMISCOE Research Series, 123–35. Cham: Springer International Publishing, 2020. http://dx.doi.org/10.1007/978-3-030-51241-5_8.

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Abstract The Danish welfare state is together with its Nordic counterparts often presented as distinct. The model has traditionally been characterised as universalist, de-commodified, residence-based, non-contributory and relatively generous. Although social protection in Denmark is still primarily tax-financed and several benefits remain universal, the Danish welfare state has undergone considerable change over time and labour market participation has come to matter more for the social protection provided. Furthermore, migrants’ access to welfare in Denmark increasingly depends on citizenship and EU related worker status. Residence clauses have been adopted for specific benefits. Eligibility depends on years resided in Denmark, unless the applicant qualifies as a worker according to EU law and therefore can aggregate periods of residence from one or several other EU Member States. In sum, social protection in Denmark has become more multi-tiered and more EU commodified.
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Conference papers on the topic "Tax residency"

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Khan, E. K., M. Meier, J. Brinton, T. M. Lockspeiser, and D. R. Liptzin. "Pulmonary Resident BootCamp: A Novel Subspecialty Preparatory Curriculum for Pediatric Residents." In American Thoracic Society 2019 International Conference, May 17-22, 2019 - Dallas, TX. American Thoracic Society, 2019. http://dx.doi.org/10.1164/ajrccm-conference.2019.199.1_meetingabstracts.a1369.

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Li, Ying, and Yuan Li. "The Impact of Tax Structure on Residents’ Consumption in China." In 4th International Symposium on Business Corporation and Development in South-East and South Asia under B&R Initiative (ISBCD 2019). Paris, France: Atlantis Press, 2020. http://dx.doi.org/10.2991/aebmr.k.200708.020.

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Androsova, V. A., and V. A. Yakimova. "ESTIMATION OF THE TAX LOAD OF RESIDENTS PRIORITY SOCIO-ECONOMIC DEVELOPMENT AREAS OF THE AMUR REGION." In CONTEMPORARY ECONOMIC PROBLEMS OF RUSSIA AND CHINA. Amur State University, 2021. http://dx.doi.org/10.22250/medprh.40.

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The article provides a calculation and analysis of the dynamics of indicators of the tax burden for priority socio-economic development area (PSEDA) residents at the stage of operation, their comparison with industry-specific types of economic activity. The conclusion is made about the expediency of using the selected indicators, about the level of tax burden and the effectiveness of benefits.
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Chen, Chuan Lin, and Jing Xue. "Impact of Personal Income Tax Reform on Income Redistribution from Residents' Subjective Perception." In 2020 International Conference on Wireless Communications and Smart Grid (ICWCSG). IEEE, 2020. http://dx.doi.org/10.1109/icwcsg50807.2020.00084.

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Cai, W. X., and F. Zhu. "A research about the effect of tax structure on urban residents' consumption in China." In 2013 International Conference of Information Science and Management Engineering. Southampton, UK: WIT Press, 2013. http://dx.doi.org/10.2495/isme131442.

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Fantozzi, Francesco, Simone Colantoni, Pietro Bartocci, and Umberto Desideri. "Rotary Kiln Slow Pyrolysis for Syngas and Char Production From Biomass and Waste: Part 1 — Working Envelope of the Reactor." In ASME Turbo Expo 2006: Power for Land, Sea, and Air. ASMEDC, 2006. http://dx.doi.org/10.1115/gt2006-90818.

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A micro scale electrically heated rotary kiln for slow pyrolysis of biomass and waste was designed and built at the University of Perugia. The reactor is connected to a scrubbing section, for tar removal, and to a monitored combustion chamber to evaluate the LHV of the syngas. The system allows the evaluation of gas, tar and char yields for different pyrolysis temperature and residence time. The feeding screw conveyor and the kiln are rigidly connected; therefore a modification of the flow rate implies a modification of the inside solid motion and of residence time. The paper provides the theoretical and experimental calculation of the relationships between Residence Time and Flow Rate used to determine the working envelope of the reactor as a function of the feedstock bulk density and moisture content, given the actual heat rate of the electric heaters. The methodology is extendable to any rotary kiln reactor with a rigidly connected feeding screw conveyor, given its geometric and energetic specifications. Part 2 of the paper will extend the energy balance introducing also the yields of pyrolysis products.
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"Tap Water Quality Assessment of Pilgrim’s Residence Buildings by Using Water Quality Index." In IBRAS 2021 INTERNATIONAL CONFERENCE ON BIOLOGICAL RESEARCH AND APPLIED SCIENCE. Juw, 2021. http://dx.doi.org/10.37962/ibras/2021/67-69.

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Souza, Tony José de, Júlia Maria Vicente de Assis, Jussara Conceição Santos Pires, and Solange da Silva Lima. "Tendência temporal da aids na população masculina de Mato Grosso, Brasil, 2009–2019." In XIII Congresso da Sociedade Brasileira de DST - IX Congresso Brasileiro de AIDS - IV Congresso Latino Americano de IST/HIV/AIDS. Zeppelini Editorial e Comunicação, 2021. http://dx.doi.org/10.5327/dst-2177-8264-202133p190.

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Introdução: A aids é uma doença causada pelo vírus do vírus da imunodeficiência humana, que é um retrovírus adquirido principalmente por via sexual (sexo desprotegido) e sanguínea, por meio de objetos perfurocortantes contaminados. Objetivo: Analisar a tendência temporal da taxa de detecção da aids na população masculina residente em Mato Grosso, Brasil, 2009-2019. Métodos: Estudo ecológico, do tipo série temporal, pautado em dados secundários do censo demográfico de 2010 do Instituto Brasileiro de Geografia e Estatística e do Sistema de Informação de Agravos de Notificação. A população do estudo foi composta pela taxa de detecção da aids registrada na população masculina residente em Mato Grosso, 2009 a 2019. Os dados do estudo foram coletados em etapa única, no período compreendido entre 17 e 18 de janeiro de 2021 por meio de acesso ao sítio do Departamento de Informática do Sistema Único de Saúde e Instituto Brasileiro de Geografia e Estatística. A estimativa da taxa de detecção de aids foi realizada por meio de estatística descritiva, na qual TDAIDS = total de casos novos de aids registrados na população masculina/população masculina residente em Mato Grosso no periodo do estudo X 100.000 habitantes. Para realização do estudo obedeceu- -se aos dispositivos contidos na Resolução n. 466/2012 do Conselho Nacional de Saúde. Resultados: Ao longo dos anos do estudo, foram registrados 9.233 casos de aids na população masculina, e a taxa de detecção registrada em 2010 era de 23,4/100.000 habitantes, saltando para 26,6/100.000 habitantes em 2015 e 34,2/100.000 habitantes em 2019. Conclusão: Os achados evidenciam tendência crescente da taxa de detecção de aids na população masculina residente em Mato Grosso e reforçam a necessidade do enfrentamento da epidemia de aids no estado por meio de ações de promoção a saúde e prevenção de doenças. Ressalta-se, ainda, a necessidade de políticas de saúde direcionadas à população masculina.
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Yılmazcan, Dilek, and Cansu Dağ. "Financial Regulations in the Field of Energy Policies." In International Conference on Eurasian Economies. Eurasian Economists Association, 2018. http://dx.doi.org/10.36880/c10.02036.

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Goals set by governments in energy field can be various. However, financial regulations can also vary depending on geopolitical location, sources, economical structure and other prioritized policies of the countries. Modern energy policies basically prioritize energy safety, efficiency, diversity and their environment-friendly features. In this study, financial regulations in the field of energy at world will be analyzed and the impact of financial regulations will be ascertained. Energy end-user price is calculated by taking taxes, CO2 emission pricing and subsidies into account. CO2 emission pricing resulting from emission top level and trade or carbon taxes affects investment decisions in energy industry by changing the costs of other competitive sources. In addition to this, major types of energy subsidies are fossil source subsidies and renewable energy subsidies. Financial policy tools in EU can be listed as energy taxation, EU emission trade system and incentives for renewable energy. Legal regulations affecting energy field in Turkey can be examined in three categories; energy taxation, tax expenditures and support mechanisms. Tax expenditures and support mechanisms covering tax exemption, exception, reduction and similar practices in energy field are provided to both producers and consumers. As a result, activating energy policies depends on decisions of many industries and individuals especially in transportation, industry and residence. These regulations mentioned in this study will be the most important tool in guiding rational preferences of the agents on generation, distribution, consumption and savings, if they are planned according to energy policies.
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Fantozzi, Francesco, Simone Colantoni, Pietro Bartocci, and Umberto Desideri. "Rotary Kiln Slow Pyrolysis for Syngas and Char Production From Biomass and Waste: Part 2 — Introducing Product Yields in the Energy Balance." In ASME Turbo Expo 2006: Power for Land, Sea, and Air. ASMEDC, 2006. http://dx.doi.org/10.1115/gt2006-90819.

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A micro scale electrically heated rotary kiln for slow pyrolysis of biomass and waste was designed and built at the University of Perugia. The reactor is connected to a scrubbing section, for tar removal, and to a monitored combustion chamber to evaluate the LHV of the syngas. The system allows the evaluation of gas, tar and char yields for different pyrolysis temperature and residence time. The feeding screw conveyor and the kiln are rigidly connected; therefore a modification of the flow rate implies a modification of the inside solid motion and of residence time. Part I of the paper describes the theoretical and experimental evaluation of the working envelope of the reactor, as a function of feedstock density and humidity content, to obtain pyrolysis conditions inside the kiln. This paper describes the development and resolution of an energy balance of the reactor under pyrolysis conditions. Once the rotational speed n is fixed, the aim of the balance is to obtain the composition of the yields of the pyrolysis of wood biomass, in terms of syngas, tar and char. Results can be used to choose the correct rotational speed before doing the real pyrolysis test.
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Reports on the topic "Tax residency"

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Michel, Bob, and Tatiana Falcão. Taxing Profits from International Maritime Shipping in Africa: Past, Present and Future of UN Model Article 8 (Alternative B). Institute of Development Studies (IDS), November 2021. http://dx.doi.org/10.19088/ictd.2021.023.

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International maritime shipping is an essential part of global business. Since the establishment of the current international tax regime in the 1920s, there has been a consensus that profits generated by this business are taxable only in the residence state –the state where the shipowners are located. Source states – the port states where business physically takes place – are generally expected to exempt income from international shipping. This standard is currently reflected in Article 8 of the OECD Model and Article 8 (Alternative A) of the UN Model, and is incorporated in the vast majority of bilateral tax treaties currently in force. Exclusive residence state taxation of shipping profits is problematic when the size of mercantile fleets and shipping flows between two states are of unequal size. This is often the case in relations between a developed and developing country. The latter often lack a substantial domestic mercantile fleet, but serve as an important revenue-generating port state for the fleet of the developed country. To come to a more balanced allocation of taxing rights in such a case, a source taxation alternative has been inserted in UN Model Article 8 (Alternative B). From its inception, Article 8B has been labelled impractical due to the lack of guidance on core issues, like sourcing rules and profit allocation. This gap is said to explain the low adoption rate of Article 8B in global tax treaty practice. In reality, tax treaty practice regarding Article 8B is heavily concentrated and flourishing in a handful of countries in South/South-East Asia – Bangladesh, India, Indonesia, Myanmar, Pakistan, the Philippines, Sri Lanka and Thailand. All these countries subject non-resident shipping income to tax in their domestic income tax laws. Except for India, all countries are able to exercise these domestic tax law rules in relation to shipping enterprises located in the biggest shipowner states, either because they have a treaty in place that provides for source taxation or because there is no treaty at all and thus no restriction of domestic law. None of the relevant tax treaties contain a provision that incorporates the exact wording of Article 8B of the UN Model. If other countries, like coastal countries in sub-Saharan Africa, are looking to implement source taxation of maritime shipping income in the future, they are advised to draw on the South/South-East Asian experience. Best practice can be distilled regarding sourcing rule, source tax limitation, profit attribution and method of taxation (on gross or net basis). In addition to technical guidance on tax, the South/South-East Asian experience also provides important general policy considerations countries should take into account when determining whether source taxation of maritime shipping profits is an appropriate target for their future tax treaty negotiations.
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Tolani, Foyeke, Betty Ojeni, Johnson Mubatsi, Jamae Fontain Morris, and M. D'Amico. Evaluating Two Novel Handwashing Hardware and Software Solutions in Kyaka II Refugee Settlement, Uganda. Oxfam, November 2020. http://dx.doi.org/10.21201/2020.6898.

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The Promotion and Practice Handwashing Kit (PPHWK), a robust, user-friendly handwashing station, and Mum’s Magic Hands (MMH), a creative hygiene promotion strategy, were evaluated in a clustered randomized controlled trial in Kyaka II refugee settlement in Uganda. The trial evaluated whether their provision increased handwashing with soap practice among residents, with a focus on three community intervention arms and two school-based intervention arms. The findings outlined in this report suggest that exposure to both the PPHWK and MMH increased hygiene knowledge and handwashing behaviour with soap, and improved health outcomes. Intervention households also preferred the PPHWK over existing handwashing stations, typically a basic bucket with a tap.
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Lederman, Jaimee, Peter Haas, Stephanie Kellogg, Martin Wachs, and Asha Weinstein Agrawal. Do Equity and Accountability Get Lost in LOSTs? An Analysis of Local Return Funding Provisions in California’s Local Option Sales Tax Measures for Transportation. Mineta Transportation Institute, February 2021. http://dx.doi.org/10.31979/mti.2021.1811.

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This study explores how local return provisions of local option sales taxes (LOSTs) for transportation are allocated and spent to meet local and regional transportation needs. Local return refers to the component of county LOST measures that provides funding directly to municipalities in the county to be used to meet local needs. Local return has become a fixture in LOSTs; 58 LOST measures placed on the ballot in California (as of 2019) that have included local return in their expenditure plan have an average of 35% of revenues dedicated to local return. Local return provisions in the ballot measures often contain guidelines on how a portion of the money should be spent. The allocation of local return funds to localities has rarely been discussed in research, and spending decisions have to our knowledge never been analyzed. This paper conducts a mixed-methods analysis of all LOSTs with local return, relying on ordinances and other public documents related to local return expenditures, and supplemented with interviews with officials in six counties. Findings indicate that local return provisions are crafted to balance the needs of the county across different dimensions, including trying to achieve equity between urban and rural residents, investment in different transportation modes, and meeting both local and regional policy needs. Moreover, significant accountability mechanisms provide regulations to ensure that funds are distributed to and spent by jurisdictions as promised by the measures. Overall, this research finds that local return is a vital part of LOST measures in California, allowing cities to meet local needs ranging from maintenance of local streets to funding for special programs, while simultaneously aligning local investment with regional priorities.
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