Which Legal Entity Is Correctly Paired with the Party That Bears

NATIONALITY PRINCIPLE – A TAXPAYER`S NATIONALITY MAY AFFECT HOW IT IS TAXED AND THE NATURE OF ITS TAX BURDEN, BUT COMPREHENSIVE TAX TREATIES GENERALLY STIPULATE THAT FOREIGN TAXPAYERS SHOULD NOT BE TAXED IN A DISCRIMINATORY MANNER BECAUSE OF THEIR NATIONALITY. NEGATIVE INCOME TAX – A proposed system to provide financial assistance to individuals and families living in poverty, using existing income tax collection mechanisms. Low-income individuals or families would receive a direct subsidy called a negative income tax. NEGLIGENCE – Failure to do what a reasonable and usually prudent person would do in the circumstances. NET INCOME – Net income is gross income less income-related deductible expenses. Many countries levy income tax on this basis. NET OPERATING LOSS – Amounts by which business expenses exceed income in a taxation year. The operating losses of an economic operator represent, broadly speaking, the excess of its operating expenses over the revenue of its activity. NET INCOME – The difference between transaction income and deductible operating expenses, subject to any tax adjustment.

Net profit margin — Ratio of operating income to gross income (or receipts) NET WEALTH TAX — See: Wealth tax Net working capital — Current assets minus current liabilities. NET WEALTH TAX – Many European countries levy a wealth tax as part of the wealth tax. The tax base of resident taxpayers is generally the taxpayer`s worldwide net assets, i.e. total assets less liabilities, deductions and exemptions expressly permitted by tax laws. NEXUS link. — Often a requirement in tax law to determine tax liability or deductibility. For example, expenses are deductible if they are “related” to gross income. In the United States, the taxable income of a multi-state corporation can only be attributed to a particular state if the corporation has a sufficient connection to the state. NOMINAL CAPITAL – amount of capital defined as such in the articles of association. Typically, a certain minimum amount of share capital is required to create a legal entity.

NOMINAL VALUE — See: Nominal value REGISTERED SECURITIES — See: Registered securities NON-DISCRIMINATION — Tax treaties often contain a “non-discrimination article” which stipulates that citizens or nationals of one country who reside in the other country may not be subject to local taxation different from that imposed on citizens and nationals of the host country in the same circumstances. (including residence). NON-QUALIFYING STOCK OPTION – A STOCK OPTION THAT DOES NOT MEET THE INCENTIVE STOCK OPTION REQUIREMENT UNDER U.S. TAX LAW. The gap is taxed as ordinary income. NON-RECOURSE DEBT – A debt for which a person has no personal responsibility. For example, a lender may take the assets given as collateral to repay a debt, but has no recourse to other assets of the borrower. NON-RESIDENT – Basically, a person who spends most of the calendar year outside their country of residence. Non-residents are generally taxed on income from sources located in the tax jurisdiction, while residents may be taxed on worldwide income.

NON-RESIDENT ALIEN – A non-resident person who is not a citizen or national of the tax jurisdiction. TAX ASSESSMENT – A written decision of the tax authorities after reviewing a taxpayer`s tax return, which determines the amount of taxable income and calculates the amount of tax owing. NOTICE — See: Deficiency 53 1 Alcohol produces a drug disulfiram reaction that causes serious MAINTENANCE COSTS — 1. Expenses incurred by a taxpayer to support his or her family, former spouse or other family members. 2. the costs of maintaining or maintaining a building or equipment. MISCONDUCT – Inappropriate or immoral conduct by a professional in the performance of his or her duties, intentionally or through negligence or ignorance; Often applied to accountants, accountants and lawyers to denote the careless or clumsy execution of tasks where professional skills are mandatory. MANAGEMENT, PLACE OF — See: Seat of management MANAGEMENT, PLACE OF ACTUAL MANAGEMENT — See: Place of effective management ADMINISTRATIVE EXPENSES — In general, administrative expenses are deductible in order to generate the taxable profits of a business carrying on a business. In the case of a group of companies, it may be important to decide to what extent the general costs of managing the group are to be invoiced and reimbursed by the members of the group. ADMINISTRATIVE FEE – Generally, fees or charges for management and/or administrative services provided by a parent company or head office. MANAGEMENT SERVICE — See: MAP intra-group services — See: MAP APA mutual agreement procedure — See: BAPA MARGINAL TAX OF TAX — The tax rate applicable to the top or upper range of income or other taxable income of a taxpayer when the corresponding tax is levied on those items at graduated rates.

NEGOTIABLE SECURITIES — See: Listed securities INTANGIBLE MARKETING — An intangible asset that deals with marketing activities that contribute to the commercial exploitation of a product or service and/or have a significant advertising value for that product. MARK-TO-MARKET – A tax and/or accounting agreement under which the value of assets/liabilities is adjusted to reflect the fair value at a given point in time. MARK-up – An increase in the price of something, especially the price a merchant pays for something, to the price at which they sell it. In the transfer pricing context, one method of estimating an arm`s length price for transactions between associated companies is to increase the supplier`s costs through a reasonable mark-up (cost-plus method). MEMORANDUM OF UNDERSTANDING (MOU) — Under a tax treaty, a document exchanged between the parties setting out the parties` agreement to the agreement. Usually, this does not have contract status, but the status depends on the document itself. MERGER – A term commonly used to describe a set of transactions involving the reorganization of companies. MINING ROYALTIES – Periodic payments, generally based on the quantity or price of minerals extracted, made by mining companies to nation states or other owners of mineral resources in exchange for the right to exploit certain mineral resources. MINIMUM TAX – In some countries, companies are still subject to a certain annual tax, whether or not they have made a profit.