A Study on the Recognizing Republic of China Source Income from Cross-border Intangible Assets Transaction
| Autor: | Jing-ru Wu, 吳靖如 |
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| Rok vydání: | 2010 |
| Druh dokumentu: | 學位論文 ; thesis |
| Popis: | 98 Due to technology advances and the complexity of the service patterns, the type of cross-border intangible assets transaction becomes diversified and complicated, which makes it difficult to classify the taxable income. Considering the tax policies, legislators formulate calculation for various incomes, for example, the recognition of Republic of China Source Income and the taxes preferential policies, etc. The Income Tax Law provides different tax effects for each category of income, which have been enforced for many years. As to the taxation of intangible assets transactions, the most controversial issue in income recognition is the reception of remuneration for technical service rendered. The tax model conventions in our country or in other countries, or the international tax model conventions, have different rules for intangible assets transaction ―that they should be the payments recognized as the service fee, royalties or other income. In the Republic of China, the income tax acts of remuneration for service rendered are income from sources in the Republic of China. However, the tax authorities often have different opinions when the act is put into practice. Even the judicial decisions are inconsistent in recognizing remuneration for service. The uninterrupted dispute exists between the tax authorities and taxpayers. The crux point of the dispute is that the tax authorities usually promulgate taxation without clear standards of economic behavior, and then interpret the taxation right as taxable income by using administrative explanations. |
| Databáze: | Networked Digital Library of Theses & Dissertations |
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