|
Page |
| Part I. — GENERAL DESCRIPTION OF INCOME-TAX SYSTEM |
235 |
| 1. Taxpayers: |
|
| (a) Individuals |
235 |
| (b) Partnerships |
235 |
| (c) Companies |
236 |
| 2. Taxable Income |
236 |
| 3. Assessment of Tax |
236 |
| 4. Collection of Tax |
237 |
| Part II. — METHODS OF TAXING FOREIGN AND NATIONAL ENTERPRISES: |
|
| A. Foreign Enterprises |
238 |
| B. National Enterprises |
240 |
| Part III. — METHODS OF ALLOCATING TAXABLE INCOME: |
|
| A. Foreign Enterprises with Local Branches or Subsidiaries: |
|
| I. General Questions and Methods of Apportionment: |
|
| (a) Book-keeping and Accounting Requirements |
241 |
| (b) Methods of Allocation |
241 |
| 1. Method of Separate Accounting |
243 |
| 2. Empirical Methods |
243 |
| 3. Method of Fractional Apportionment |
243 |
| 4. Requirements for Selection of Methods and Relative Value of the Various Methods |
245 |
| (c) Apportionment between Branch and Parent Enterprise: |
|
| 1. Apportionment of Gross Profits of Branch to Real Centre of Management abroad |
246 |
| 2. Apportionment of Expenses of Real Centre of Management to Branch |
247 |
| 3. Apportionment of Net Profits of Branch to Deficitary Parent or vice versa |
247 |
| (d) Apportionment between Parent Enterprise and Subsidiaries |
247 |
| II. Application of the Methods of Allocation in Specific Cases: |
|
| (a) Industrial and Commercial Enterprises: |
|
| 1. Selling Establishments |
249 |
| 2. Manufacturing Establishments |
249 |
| 3. Processing Establishments |
250 |
| 4. Buying Establishments |
250 |
| 5. Research or Statistical Establishments, Display Rooms |
250 |
| (b) Banking Enterprises |
250 |
| (c) Insurance Companies |
250 |
| (d) Transport Enterprises |
250 |
| (e), (f) and (g) Power, Light and Gas Enterprises, Telegraph and Telephone Enterprises and Mining Enterprises |
251 |
| B. National Enterprises with Branches or Subsidiaries abroad |
251 |
| C. Holding Companies |
251 |
| ANNEX: Income-Tax Tariff |
252 |
