International Taxation国际税收 试卷4.docVIP

试 题 四 I. True or false (10 marks, 2marks/each) 1. International juridical double taxation only occures whenever there is multiple taxation on the same income of different taxpayers. ( ) 2. There are two types of tax jurisdiction: Source jurisdiction and citizen jurisdiction. ( ) 3. Foreign-source income earned by residents of a country that uses the deduction method generally is taxable at a higher effective rate than it would be under either the credit method or the exemption method.( ) 4. Many countries use the presence period criterion to identify the residence of individual.( ) 5. The chief difference between the UN Model treaty and OECD Model Treaty is that the UN Model Treaty imposes fewer restrictions on the tax jurisdiction of the source country.( ) Ⅱ．Please explain the following key terms. (12 marks,3 marks for each key term ) 1. Residence tax jurisdiction 2. 3. arm’s length price 4. transactional net margin method Ⅲ. Questions ( 28 marks ) 1. Please explain what methods may be used by resident country to eliminate the international double taxation caused by the conflicts between the residence jurisdiction and source jurisdiction.(4 marks) 2. please explain the meaning of unlimited tax liability,and who will bear the unlimited tax liability. (3 marks) 3. Please explain the differences between branch and subsidiary.(6 marks) Please explain the operation of a direct conduit company by a figure.(6 marks) Please explain the main features of arm’s length principle and principle of Global Apportionment. (8 marks) Ⅳ. Case Study ( 20 marks ) 一 De Beers Consolidated Mines, Limited was incorporated in South Africa and its main business, eg, diamond mining, processing was in South Africa. Its head office was set in Kimberley(金伯利）, also it had many branches in other countries. The companys most directors lived in London, and the board meetings mostly were held in London. In 1906, the British