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The two finest criteria’s for levying tax used by the international comity since long are
Residence test: This rule was adopted by UK, USA & Japan, a strategy to tax the residents on their world wide income. However this came along with the package of issues relating to double taxation of the MNCs.
Source test: - Source is strongly associated with the physical presence of the income or an aspect of the transaction producing the income within the territory of the state. However this conflict is due to the multiplicity of sourcing rules.
Throughout the history, of mankind, power play and politics have resulted in growth of the Multinational corporations and subsequent development of time instituting policies that allow them reap the benefit of tax saving policies. The crux of all the wars lied in passion to gain edge and control over the acquisition of wealth, resources and the maintenance of the hegemonic structures all over the inhabited surface of the earth. Today a considerable number of MNCs wield momentous power, wealth and confidence
that are lager than many nations. These entities are not bit players in the global
economy. The top 500 corporations, for example, control almost one third of global GNP and 76 percent of world trade. Their influence continues to grow. According to UNCTAD figures, TNCs controlled 17 percent of global GNP in the 1960s. This had jumped to 24 percent by 1984 and pushed ahead to 33 percent by 1995. Presumably this share has increased since then. Another way to look at this growing control of the global
economy by TNCs is to realise that the sales of the world's 10 largest TNCs exceed the
combined Gross National Product (GNP) of the world's 100 "least developed" (economically) countries. This includes whole of Africa.
Tax Avoidance And Tax Planning.
Every sovereign nation has a guideline that determines the taxability of the income of the assesee. Tax avoidance is the legal utilization of the tax regime to one's own advantage, in order to reduce the amount of tax that is payable by means that are lawful. By contrast tax evasion is the general term for efforts made for not paying taxes by illegal means. The term tax mitigation is a synonym for the tax avoidance. Its original use was by tax advisors as an alternative to the pejorative term tax avoidance
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