AS2: Comparative Case Study

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A QUALIFIED TAX REPORT IN INDIVIDUAL CIRCUMSTANCES.

Student Name: Ruth Maneesha Evanjalin Gomis

Student ID: 4659/ 23824989

Student Name: Ruth Maneesha Evanjalin Gomis

Student ID: 4659/ 23824989

Date: 08th April 2023

Module: International Tax Systems
Lecture Name: Mr. Dimuthu Heenpella
Code: ACC3024
Word Count: 2500

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AS2: Comparative Case Study

Acknowledgement
I was given the opportunity to finish my report by Mr. Heenpella, my international taxation
instructor, who also provided me with wise counsel. I am grateful for my parents' support and
sacrifices, as well as for their energy, vision, sincerity, and ambition. My husband and daughter
also helped me finish my report, and I am grateful for their support, love, and intercession.
I would like to express my gratitude to my friends and research associates for their unwavering
support in the preparation of this study.
Last but not least, I'd like to express my gratitude to everyone who helped finish the report in
whatever form.

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AS2: Comparative Case Study

Table of Content

Acknowledgement..................................................................................................................................2
Introduction..............................................................................................................................................4
1.0 CHALLENGES OF DOUBLE TAXATION AND THE OPPORTUNITIES FOR
HARMONIZATION...................................................................................................................................5
Task 01:- Resident, non- resident, Double tax, Double tax Treaty................................................5
2.0 COMPLEXITY OF VARIOUS NATIONAL TAX SYSTEMS...................................................6
Task 02. : - employment tax and self-employment tax....................................................................6
2.1 Employment Tax...................................................................................................................6
2.2 Self- employment Tax...........................................................................................................6
2.3 Difference between Self-employment and employee............................................................7
2.3 Capital gains tax exemptions and rules.............................................................................9
Task 03:- Individual Income tax........................................................................................................10
3.1 - 1st option: - stay in UK and work in headquarters.................................................................10
3.2 - 2nd Option: - move to China and work in the branch for a period of 12 months.............12
Task 4:- Corporation income tax......................................................................................................14
4.1 UK Tax Liability.............................................................................................................................14
4.2 Tax payable to other countries...................................................................................................16
4.3 Suggestions to Harrison ltd on how to reduce their total tax liability.....................................17
4.3.1 Using Transfer Pricing..........................................................................................................17
4.3.2 Use Thin Capitalization........................................................................................................17
4.3.4 Using Tax Havens.................................................................................................................18
4.3.4 Using Trust Funds.................................................................................................................18
References.............................................................................................................................................19

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AS2: Comparative Case Study

Introduction
The Advisor identifies the impact of various tax systems on corporate income taxes in China
and the UK, the rule of double tax treaties to address the issue of dual residency, current
employment, self-employment, and trades license regulations, and current individual income tax
regulations in the UK and China are all examined in this report. The Advisor also identifies and
advise to the individual tax pays and also the MNC. In this advice report the adviser identifies
the methods that the corporations apply in order to avoid or minimize tax liability

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AS2: Comparative Case Study

1.0 CHALLENGES OF DOUBLE TAXATION AND THE

OPPORTUNITIES FOR HARMONIZATION

Task 01:- Resident, non- resident, Double tax, Double tax Treaty

Sandra is a resident and domiciled person in the UK as a result of the automatic UK Test.
Applying the test 1, Sandra will be regarded as a UK resident since, unless she accepts the
China offer and remains in the UK for more than 183 days, she will be regarded as a UK
resident for that tax year.
According to the UK residency test 2, a person is regarded as a resident of the UK if they keep
a house there for all or a portion of the tax year. Due to her property and potential time spent
there over 30days or 91days in UK, Sandra is considered a resident of the UK. If she accepts
the offer from China, she will not fall under test 3, thus because of her property and her length of
residence in the UK, she will be regarded as a UK tax resident.
A person must have a permanent registered address, a family or economic interest in China, as
well as have been there for at least 183 days within a tax year, in order to be designated a
resident of that nation. Sandra made a three-year employment offer in China. She is regarded a
Chinese tax resident since she has a job that is an economic interest and will be in China and
employment duration for more than 183 days therefore she is considered as a Chinese tax
resident Her taxable income would include both income from within and outside of China.
When a resident of one country has access to money or earnings produced in another,
international tax can get tricky (OECD, 2011). The source and residence principles overlap,
hence there is a double taxation issue .As per OECD model tax convention definition of
Resident of a contracting state means any person who by the laws of that state is liable to tax
by reason of his domicile, residency and place of management or any other criteria by the
political or local authority. Therefore Sandra is liable to UK tax because she is a UK resident
and she is liable to China tax because she is a China resident.
Where an individual is considered a resident of both states within reason of the above definition
of OECD, then his status will be determined as will be considered a resident of the state that
she has a permanent home. In this case Sandra permanent home is in UK, she will be
considered as a UK resident only.
In Concluding Sandra resides in the UK and has a UK domicile. She won't be regarded as a
resident of China under OECD convention. Sandra will therefore pay taxes on the money she
earned in China to Chinese tax authority and property she has in UK to UK tax authority.
Addition to that her Chinese employment income will be exempted from the UK tax.

If Sandra does not accept the offer. She would have to pay the SDLC tax for the property she
owns. And employment income tax for the salary she receive in UK. If she accept the offer she
will be liable to employment income tax in China, but still need to pay SDLC in UK. Her
employment income in China will be exempted from UK tax.

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AS2: Comparative Case Study

2.0 COMPLEXITY OF VARIOUS NATIONAL TAX SYSTEMS

Task 02. : - employment tax and self-employment tax

2.1 Employment Tax

Employment is an economic situation in which labor resources are used efficiently.

Employment income is the total earnings of an employee that arise from an employment
relationship. Bonuses, commissions, Expense allowances, Fees, Payments on
termination, pensions arising from an employment and Benefits in some kind should be
added to employment income. If given by the employer, living quarters are regarded as a
taxable benefit, any contributions made by the employee are taken into account in
determining the taxable benefit. A beneficial loan is one that a company offers to a
worker or a family member of a worker that is either interest-free or has a lower interest
rate than the going rate.
After adding all the expenses and all allowances of any benefits from the employment,
Taxable employment income will be computed. Under the PAYE system, the amount of
tax to be deducted from the employee’s remuneration or total earnings is calculated. A
standard personal allowance of £12,570 is the amount of income considered as a tax
free allowance from taxable income. The following rates apply for each band of income
earned within the tax year.

2.2 Self- employment Tax

Any individual who runs their own business and is responsible for its success or failure is
regarded as self-employed. They do not have the same employment rights and responsibilities
as workers because they are not paid through PAYE. They must classify their operations as
either trading or non-trading ones in order to estimate their taxable revenue. Important factors to
take into account when determining whether an activity belongs in the trading or non-trading
category include the subject matter, length of ownership, frequency of transactions,
supplemental employment, justification for selling, and motive.

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AS2: Comparative Case Study

2.3 Difference between Self-employment and employee

Basis of Comparison Self- employed Employee

State working for working for an
yourself employer

Working Condition People either run their standard

own businesses or individuals work
work as independent
contractors for other
under contract
companies. for a company
Risks and freedom has a lot of freedom. No freedom
poses serious dangers No risks
Expenses Pays for all costs and Doesn’t pay : paid by
expenses employer
Social Benefits Pays the social The contributions are
security contributions paid for them
Maternity Leave selects the vacation 15 weeks off
days.
Illness and accidents No income when they Paid by the employer
become unwell when ill
Holidays and No paid leave Paid leave
employment Enjoys unemployment
benefits
Position In charge of the Not in charge under
business authority
Advantages  Flexibility.  access to
 Independence. certain
 Freedom
 High earning
benefits
potential.  greater job
 A better work life security
balance  Regular

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AS2: Comparative Case Study

Income
 access
numerous
growth and
networking
opportunitie
s
Income Revenue may monthly
fluctuate as compensatio
going through
periods where no
n is the
work is available. same, thus
money is
consistent.
earning potential Likely to Employers set
make more prices based on
qualifications and
money and experience.
set their own
prices.
Tax Taxes must be paid Pay tax
through a self- automatically
assessment through PAYE
Benefits don't acquire paid rewards.
any consisting of health,
dental, and life
advantages insurance
until they
establish
them for
themselves.,
Professional Opportunitie There are countless

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AS2: Comparative Case Study

Development s for prospects for career

professional advancement and
professional
development development.
and self-
improvement
depend on
your
initiative and
capacity to
network with
other
industry
experts.
Responsibilities Manage all parts of only be held
business or
workload, from accountable for
finance and errors you make
accounting to tax
and sales, and carry
on your allocated
out, manage, and work..
oversee daily
operations.
Responsible for any
possible mistakes.
Work Life As you are occasionally
Balance your own work long hours,
boss and disrupting your
make your work-life balance
own
schedules,
you can find

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AS2: Comparative Case Study

time for your

loved ones,
friends,
interests,
and other
obligations.

2.3 Capital gains tax exemptions and rules

When an asset is sold, capital gains are the rise in value. When an asset is sold, they are
typically realized by deducting the original cost from the sale price. In some cases, the IRS
levies personal capital gains taxes. For some stocks and collectibles, as well as if the income
exceeds the 15% level, capital gains are taxed at a higher rate. Losses are not deductible,
although the first $250,000 of the sale price of a principal residence is tax-free. Short-term gains
are taxed at the ordinary income tax rate, whereas long-term gains might be taxed at 0%, 15%,
20%, or 25% depending on income, filing status, and asset type.

Task 03:- Individual Income tax

3.1 - 1st option: - stay in UK and work in headquarters

David Annual Salary £275,000

(+) disallowable Benefit
Accommodation Benefit Note 01 8,875
Running cost Note 02 1,000
Beneficial Loan Note 03 500
Gym facility Note 04 650

Motor Vehicle
1st 6 Months -Millage Note 05 1250
Last 6 Months - Usage Note 06 6840 19115

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AS2: Comparative Case Study

(-)allowable expenses
professional subscription Note 07 1300 (1,300)
Total Taxable Income 292,815

Tax payable amount by David

Personal allowance – 12,570
Basic Rate – (12571-50270 = 37700*20%) = 7540
Higher Rate – (50271-150,000= 99730*40%) = 39892
Additional Rate – (292815-150000=142815 *45%) = 64266.75
Total Income Tax liability = (7540+39892+64266.75) =£111,698.75

Note 01:- Accommodation Benefit

Computation of Living Accommodation tax

Annual Value 6,750
Accommodation Adjustment *
House Value 280,000
(+ )Cost of Accommodation -
(-) property value allowance ** (75,000)

205,000 * 2.5% 5125

(-) Employee Contribution (250*12) *** (3,000)
Taxable Benefit from Accommodation 8,875

*Living accommodation is considered a taxable benefit if provided by the employer. If the

accommodation is owned by the employer, the employee will be taxed on the annual value,
** The additional amount by which the cost of accommodation exceeds £75,000 will be
multiplied by the official rate of interest as at the beginning of the tax year for which the benefit
is being calculated.
***The cost of accommodation is equal to the purchase price plus any costs of improvements
made before the start of the tax year, minus any capital contribution made by the employee.
**** David contributes towards its running costs which cost the company £1,000. Since David
pays it is delectable, as a contribution to ancillary service
Note 2:- Running cost
Employers who provide housing for their employees must pay taxes on both the housing and
any additional services they offer. In this case David is provided with a house and its running
costs which cost the company £1,000.Therefore it is considered as a benefit to his income.
Note 03:- Beneficial Loan

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AS2: Comparative Case Study

David has receive a loan from his employer that is interest-free. There is taxable benefit
emerging because sum of all beneficial loans granted to an employee exceed £10,000.
Therefore Beneficial loan taxable income = 20,000*2.5% = 500
Note 04:- Gym
Since employee David is benefited by the gym facilities provided by the company therefore
benefit of accessing the Gym will increase taxable benefit.
Note 05:-Motor Vehicle (tax on Motor vehicle of 1st 6 months)
David actually receive (13000miles * 0.50) = 6500
David receive tax free millage allowance (10000*0.45) + (3000*0.25) = (5250)
David’s taxable millage allowance = 1250
 employees who use their private vehicles for business use subjected to the approved
mileage allowance provided by the HMRC
 For Motor cars and vans
 first 10,000 miles in tax year 45p per mile
 each mile over 10,000 miles 25p per mile
Note 06:- Tax on usage of motor vehicle for last 6 months
Unless it cannot be used for personal purposes, an employee will be taxed on the car that the
employer provides. The cost of the car is used to determine the taxable benefit, which is then
multiplied by the car's carbon dioxide emissions which is stated below.
Co2 percentage for 2019-2020
- 95g/km – 23%
- Each additional 5g/km 1% increase
- The percentage is increased by a 4% for diesel-driven cars
Since David use a diesel powered motor car above mention percentage are applicable.
Taxable allowance usage of motor car = {38000* (23%+ (45)/5 + 4%)}/2 = 6840
Note 07:- professional subscription
Subscriptions to relevant professional bodies’ expenses incurred by an employee are deductible
or allowable for tax purpose

3.2 - 2nd Option: - move to China and work in the branch for a period of
12 months
RMB

Individual Annual Income Note 01 1680000

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AS2: Comparative Case Study

Add :- Disallowed benefit

Rental allowance in cash Note 02 35000
Reimbursement of air-tickets on the third home leave in 2017 Note 04 8,500
Reimbursement of car rental for private use Note 05 12,000 55500
Deduct :- Allowable expenses
the standard allowance Note 06 60,000
Employee’s contributions on social security Note 07 5,600 (65,600)
Annual income taxable 1669900

Note 1:- Monthly Salary

When computing the annual income need to multiply by 12 in order to calculate the yearly
income because income tax rates are given in annually basis
Annual Individual income tax – 140000monthly salary *12 months = 1680,000

Note 2:- Rental allowances

It is a benefit to the employee therefore it is add back to the annual income
When determining taxable income for IIT residents, the standard allowance of 60,000 per year
deducted.

Note 3- Meal allowance and business travel and child education

Allowances for meal expenses and Business travel expenses are exempted from tax
Child education 1,000 per child per month exempted annually (1000*12=12000) In this case its
5000 and its exempted.

Note 4 – Air ticket

Only Two personal trips to the individual’s country of origin is exempted this is a 3 rd home visit
therefore it is added as a benefit to employment

Note 05:- car rental for private use

Since it is a benefit to the employee it is added to annual income
Note 06 & 07:- Deductions
The following earnings are deducted from taxable income for residents in consideration of the
IIT Standard Allowance of $60,000 annually: Contributions made by the employee to Chinese
social security

Note 08:- Annual taxable income = (1669900* 45%) - 181920 = 569535

Note 09:- Annual Bonus

In order to find the monthly taxable income annual bonus must divided by 12
Monthly taxable income – 180000/12 = 15000
Annual bonus/12)*applicable tax rate – quick deduction = Annual Bonus Tax
(180000/12) * 20% -1410 = RMB 34590
Applicable tax rate is chosen between the slabs that have 15000

Note 10:- Total Tax payable = 596535+34590= RMB 631,125

Assume 1 RMB: 0.12GBP

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AS2: Comparative Case Study

Therefore 631125*0.12= £ 75735

Professional Tax Advice:-

If we David chose the option 1 as Stay in UK. His total taxable income will be £292,815and total
tax liability to the Tax department would be £=£111,698.75 as per the computation. If he
accepted the china offer his total taxable Annual income in RMB is1669900. If RMB is converted
to GDP it would be £75735 (1RMB: 0.12GDP). Since the taxable income paid in china is less is
advised to take the Chinese Employment and pay less income tax to the government

Task 4:- Corporation income tax

4.1 UK Tax Liability

£

Net profit for the year 1,139,500

Deduct Non Trading Income
Dividend received Note 01 15,000
Income from property Note 02 9,000
Income from non-trading loan Note 03 5,000
Bank interest receivable Note 03 4,000
Profit on sale of investment Note 04 9,500
Profit on disposal of Machinery Note 05 2,000
( 44500)
Profit after above deductions 1095,000
Add Disallowed expenses
Directors' fees 80,000
Depreciation of tangible fixed assets 90,500
Customer entertaining expenses Note 06 3,000

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AS2: Comparative Case Study

Gift Aid donation paid in the year 2,000 177,500

Patent Owning Note 09 1,000
Accounting Adjustment for sale of investment Note 10 1,000
Trading Income Before Capital Allowances 1,272,500
Deduct Capital Allowances
Main pool
Vehicle – 35g/km Note 07 30,000
Main pool other Note 07 25,200
Special pool
Vehicle -140g/km
Note 08 1320

( 56520)
Trading profit adjusted for tax purposes 1,215,980

Corporate tax Rate for the year 2020/2021 main rate is 19% .There are no thresholds applicable
to year 2020/2021 Therefore corporation tax liability payable by the company to the UK
government is as follows 1,205,980*19% = £231036.20
Note 01:- Dividend received
Dividends are not included in the taxable total profits since they are paid from profits that have
already been subject to corporate tax. This prevents double taxation.
Note 02:- Income from property not considered as trading income.

Note 03:- Income from non-trading loan

interest from banks, building societies, and other sources is paid to businesses on an accruals
basis. Interest from people or other businesses is also paid out in gross. It is seen not permitted
income because it is not regarded as a trade income.
Note 04:- Profits on the disposal of non-current assets
For calculating trading profits, which are defined as Profits on the Disposition of Non-Current
Assets, non-trading revenue that appears in accounts should be subtracted.
Note 05:- Profit on disposal of machinery
The company disposed of machinery for £17,000, this machinery originally cost
£15,000.Therefore profit is (17000-15000= 2000)
Note 06:- Loss incurred on books from sales of investment
Profit shown in the book of accounts for investment is 9500

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AS2: Comparative Case Study

Note 06 :- Some charitable donations and gifts are referred to as qualifying charitable donations
and are deducted when calculating a company’s total taxable profits
Note 07 :- Main pool capital allowances
General pant and machinery, motor vans, motor cycles and lorries, and cars with emissions
below 110g/km are all allocated to this pool. The writing down allowance is calculated as a
percentage of the pool balance. Main pool at 18% per annum.
Main pool
Vehicle- motor car with emissions not exceeding 50g/km is eligible for a 100% FYA therefore
this car is 35g/KM so it is allowable for 100% which is 30000

Main pool
Opening balance 85,000
Addition
Plant 40,000
Van 30,000
Deduct
Machinery (15,000)
Asset Balance 140,000
Deduct – Capital Allowances 18% (25,200)
WDV 114,800

Note 08:;- special pool capital allowances

Cars with emission over 110g/km are allocated to this pool. Since the vehicle has C02
emissions of 140g/km it is allocated to this pool.
Vehicle – 22000*6% =1320

Note 09 :- Patent royalties receivable

This is for trade purposes, therefore it is allowable but Gross patent royalties of £7,000 and further
£1,000 was owing so it is added to the income

Note 10:- sale of investment

Profits on the disposal of non-current assets is considered as a Non-trading income. Therefore
sale of investment is deducted but chargeable gain on the sale of investments is £8,500. In books it
mention as 9500. Excess 1000 should be added to income

4.2 Tax payable to other countries

Country Taxable income Tax rate to each country Note 01 :- Tax liability of each country
in each country currency
USA £400,000 21% (federal rate) 400000*21% = £ 84000
Hong Kong 400,000*10= 8.25% (first 2Mn HKD) HK$2,000,000*8.25% =HK$165,000

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AS2: Comparative Case Study

SAR HK$4,000,000 HK$2,000,000*16.5%=HK$330,000

Total Tax Liability = HK$495,000
16.5% (rest)
HK$495000/10= £49500

Ireland £100,000 12.5% 100000*12.5% = £12,500

Vietnam £300,000 20% 300000*20% = £60,000
China £800,000 25% 800000*25% = £200,000

Singapore 500,000*1.75= 17% S$ (10000*75%)= S$ 7500 –

S$875,000 exempted
S$ 2500*17% = S$ 425
*75% of first S$ (190,000*50%) = S$ 95000-
exempted
S$10000 is exempt
S$ (190,000*50%)*17% = S$ 16150
+ 50% of next S$ (875000-10000-190000)*17%=
S$114,750
S$190000 is
exempt Total tax liability =
425+16150+114750= S$ 131,325

S$ 131,325/ S$1.75 = £75,042.86

Indonesia 250,000 22% 250000*22%= £55,000

Note 01 :-
Since Tax rate % are given by each country the taxable income has been converted to that
country currency using given exchange rates.

4.3 Suggestions to Harrison ltd on how to reduce their total tax liability

4.3.1 Using Transfer Pricing

The price at which related parties interact with one another, like when supplies or labor are
traded between departments, is known as the "transfer price." It can be applied to transactions

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AS2: Comparative Case Study

involving a parent business and its subsidiaries. Through a survey, Cravens (1997) discovered
that MNCs employ transfer pricing to gain a competitive advantage and other corporate
purposes, influencing performance measures and advancing corporate goals. When divisions
sell products to divisions in other foreign jurisdictions during intercompany transactions, transfer
prices are applied.
Additionally, it can be utilized to circumvent international tariffs on the exchange of products and
services. Harrison ltd can use transfer pricing to book higher profits in another country with a
lower tax rate and avoid tariffs on goods and services exchanged internationally. PAT
maximization and worldwide tax management can both benefit from using international transfer
pricing, according to (Korn & Lengsfeld, 2004).
Take Harrison Ltd. as an example from the above. China has a large tax burden, while Ireland
has a modest one, according to the aforementioned tax rates. More profits for the company to
emerge in Ireland, where the company will pay lesser taxes, would be advantageous to
Harrison Ltd as a whole. Assume Harrison Ltd. may then try to sell them to Ireland for less than
market value by having China offer a transfer price. As a result, China would experience
decreased sales revenue and higher overall earnings, whereas Ireland would have a lower
cost of goods sold (COGS) and higher earnings. Harrison Limited will therefore attempt to
relocate a large percentage of its economic activity to locations with lower tax rates in order to
avoid paying taxes.

4.3.2 Use Thin Capitalization

Thin capitalization is when capital is hidden by loans that go over and beyond reasonable
thresholds (Rohatgi's, 2005). A condition known as thin capitalization occurs when a firm has a
relatively high proportion of debt to equity financing. To leverage the advantages of thin
capitalization, multinational firms often structure their financial operations. To attain thin
capitalization, MNEs boost debt financing in nations with high tax rates (Mintz & Smart, 2004).
In order to transfer profits into low-tax nations for tax advantages, corporations with
headquarters in high-tax countries borrow more money or at higher interest rates from
businesses with headquarters in no-tax or low-tax countries.

In most nations, interest that has been paid or that is still owed can be subtracted from the tax
measure of profit. This means that compared to equity, debt is frequently a more tax-efficient
form of funding. Multinational firms are able to customize their financial arrangements to best
take advantage of these benefits, resulting in a tax-efficient mix of debt and equity in the
countries that borrow money as well as changing how the lender who receives the interest is
taxed. Debt financing costs, such as interest, are tax deductible. In high-tax nations, this
enables businesses to deduct interest payments from earnings or taxable income, lowering
overall tax payments.

A worldwide corporation called Harrison Ltd. has operations in the USA and Hong Kong. Its
subsidiary in Hong Kong has extended a substantial loan to its subsidiary in the United States.
As it employs excessive debt financing to shift earnings to Hong Kong, where the tax rate is
lower, and reduce its tax liability in the USA, where the tax rate is greater, this might be viewed
as having thin capitalization.

4.3.4 Using Tax Havens

Tax havens are nations or jurisdictions that impose little or no taxation on foreign citizens and
corporations without requiring them to do business or live there. A business can transfer its

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AS2: Comparative Case Study

income to a tax haven with lower tax rates from a jurisdiction with higher tax rates (Slemrod,
2004). Tax reductions in tax haven countries, which might be zero to low single digits, benefit
both individuals and businesses.

Singapore uses tax incentives, a lack of withholding taxes, and profit shifting to maintain fair
corporate rates. Due to its stable political climate and cutting-edge financial technology, it is also
a desirable location to park wealth.so it is advice to do a profit shifting to Singapore by Harrison
Ltd.
4.3.4 Using Trust Funds
Trusts are formal agreements under which a third party holds a person's assets in accordance
with specific objectives or directives. While irrevocable trusts are exempt from both estate and
inheritance taxes, revocable trusts are subject to estate tax. Trust beneficiaries may end up
owing taxes on earnings or gains produced by the trust assets after they receive them, whereas
testamentary trusts are created in the will and taxed accordingly. In order for family members to
prepare and be informed of what will happen to all of their loved one's possessions, it is crucial
to understand the many forms of trusts. Therefore MNC can create trust to deposit their
reserves and profit in order to avoid the tax imposed by the government.

References
Haegele, B. (2023) Tax havens: Examples, benefits and legality, SmartAsset. SmartAsset.
Available at: https://smartasset.com/taxes/tax-haven-examples-benefits-and-
legality#:~:text=Tax%20Haven%20Examples,-Many%20countries%20and&text=Places
%20like%20Switzerland%2C%20Bermuda%20and,investors%20to%20park%20their
%20wealth. (Accessed: April 6, 2023).

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AS2: Comparative Case Study

Kumar.r, P. (2021) How does thin capitalization affect taxation? , TaxGuru. Available at:
https://taxguru.in/income-tax/thin-capitalization-affect-taxation.html (Accessed: April 6,
2023).

Report • By Thomas L. Hungerford • March 31 (no date) The simple fix to the problem of how to
tax multinational corporations - ending deferral, Economic Policy Institute. Available at:
https://www.epi.org/publication/how-to-tax-multinational-corporations/ (Accessed: April 6,
2023).

Seth, S. (2023) Transfer pricing: What it is and how it works, with examples, Investopedia.
Investopedia. Available at: https://www.investopedia.com/terms/t/transfer-pricing.asp
(Accessed: April 6, 2023).

Tax benefits of trusts (no date) Empathy. Available at: https://www.empathy.com/taxes/tax-

benefits-of-trusts (Accessed: April 6, 2023).

Tax Haven (2022) Corporate Finance Institute. Available at:

https://corporatefinanceinstitute.com/resources/economics/what-is-tax-haven/ (Accessed:
April 6, 2023).

Team, W. (2023) Thin capitalization, WallStreetMojo. Available at:

https://www.wallstreetmojo.com/thin-capitalization/#Examples (Accessed: April 6, 2023).

Waluyo, W. and Doktoralina, C.M. (2018) “Factor affecting tax avoidance through thin
capitalisation: Multinational Enterprises in Indonesia,” SSRN Electronic Journal [Preprint].
Available at: https://doi.org/10.2139/ssrn.3436024.

Waluyo, W. and Doktoralina, C.M. (2018) “Factor affecting tax avoidance through thin
capitalisation: Multinational Enterprises in Indonesia,” SSRN Electronic Journal [Preprint].
Available at: https://doi.org/10.2139/ssrn.3436024.

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