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Volume 25, Issue 34 (9-2017)
Abstract
The multinational Enterprises resort to establishing subsidiaries in states other than their residence in most cases in order to avoid PE status. Due to the assumption of independent legal entity, subsidiaries are taxed as resident taxpayers in the place of incorporation or effective management in most states. But the high level of dependence on foreign companies has caused jurisprudence in some countries, treat subsidiaries as PE of non-resident companies under article 5 of OECD Model Treaty. Considering subsidiary as PE requires fulfillment of some conditions and this article has tried to extract applicable criteria in this respect through looking at model treaty which has been the role model for drafting Iran tax treaties. Thus it’s needed to pay attention to the substantive contractual relations between parent company and subsidiary, existing circumstances on degree of dependence among them and scope of accepted entrepreneurial risk of commercial activities in context of agency contract.
Ahmad Ezzati Shourghouli, Mahtab Zeinalzadeh, Heiro Isavi,
Volume 31, Issue 60 (2-2024)
Abstract
The present study predicts the effect of connecting the transaction of card readers to the tax affairs system on the increase in the collection of the tax affairs organization of West Azarbaijan province in 2022. The present study by forecasting the tax revenues of West Azarbaijan province based on the Data up to March 1400 has investigated this issue that if the tax revenues of West Azarbaijan province had the same trend as the previous years and the card readers was not connected The tax affairs system how much did this organization collect?. In fact, the difference between this forecast and its actual amount shows that by connecting the card readers to the tax affairs system, the collection amount of this organization has increased to what extent. For this purpose, the present study using the monthly data of the tax revenues of West Azarbaijan province during the years 2005 to 2022 and by applying three models of state space, Markov Switching and Arima models showed that the provincial tax based on the transaction performance of the card reader device has increased the percentage of realization of total tax revenues of West Azarbaijan province in 2022 by almost 32%. Also, the effect of this plan on increasing the percentage of corporate tax, personal income tax, wealth tax and indirect tax of West Azerbaijan province in 2022 was equal to 29, 11, 6 and 65% respectively. On the other hand, according to the forecast of the total tax revenues of West Azerbaijan province in 2023, It is expected that they will be realized Minimum 117 and maximum 130 percent of the approved income.
