Talk:International taxation

FIRPTA
Want FIRPTA added to this?EECavazos 23:11, 22 October 2007 (UTC)

Content on tax treaties and multistate tax schemes like EU VAT
This article could use some additional perspective of the position of tax treaties in the international taxation as well as international tax schemes like the EU VAT. Much of this article seems focused on national tax schemes for international taxation, and the amount of content on this is pretty appropriate because that is so much of what constitutes international taxation. But I suppose to add tax treaties and EU VAT would result in a slight realignment in the introductory paragraph. This would probably need some agreement or at least the chance to provide opposition to such a prospet.EECavazos (talk) 00:17, 14 May 2008 (UTC)

Peer-review
Peer review: This expanded version has been partially globalized. I'd like a reviewer with significant international tax experience to expand further and simply REVIEW it, making appropriate edits. Thanks.Sfcardwell (talk) 03:54, 26 June 2009 (UTC)


 * I don't have time to give this article a full review of the content (and I don't have a lot of international tax experience), but it has a bit to go to move to the next level of Wikipedia standards - making progress though. :-) I took a little bit of time to make some Manual of Style and Guide to Layout changes, but much more is needed in this regard.  It is in some need of wikilinks, organization, and copyedits.  The lead needs to be expanded to summarize the article.  Their needs to be more sources, particularly something in the lead that goes toward the base definitions put forward for International taxation.  The article needs to clearly define the definition in the first sentence.  After looking, the content looks greatly improved and a nice addition for sources.  There were a lot of changes recently and I think the differences need to be worked out if there is any value in the other material.  Thanks for your additions Sfcardwell. I'm going to try and give it a read through and tighten it up if I can.  There seems to be a very large focus on income taxes.  Does this field cover tarrifs, VATS, or other international taxes on imports/exports.  Does the field cover some aspects of tax competition?  How much of these concepts should be included?  Take a look at what can be merged into other sections (Other aspects is one).  Take a look at what can be grouped better, the TOC is pretty long.   Morphh   (talk) 2:13, 27 June 2009 (UTC)


 * The introduction and overview needs to be merged into the lead (that's its purpose) or distributed to the particular introductory subsections. Many of the references are personal comments or primary sources that could be subject to much interpretation, please try to use reliable secondary sources whenever possible and avoid original research.  If it is an opinion, then try to attribute it.  Morphh   (talk) 14:00, 27 June 2009 (UTC)

The following suggestions were generated by a semi-automatic javascript program, and might not be applicable for the article in question. You may wish to browse through User:AndyZ/Suggestions for further ideas. Thanks, Morphh   (talk) 13:22, 27 June 2009 (UTC) 13:22, 27 June 2009 (UTC)
 * Please expand the lead to conform with guidelines at Lead. The article should have an appropriate number of paragraphs as is shown on WP:LEAD, and should adequately summarize the article.[?]
 * Consider adding more links to the article; per Manual of Style (links) and Build the web, create links to relevant articles.[?]
 * This article has no or few images. Please see if there are any free use images that fall under the Image use policy and fit under one of the Image copyright tags that can be uploaded. To upload images on Wikipedia, go to Special:Upload; to upload non-fair use images on the Wikimedia Commons, go to commons:special:upload.[?]
 * Per Manual of Style (headings), avoid using special characters (ex: &+{}[]) in headings.
 * Per WP:WIAFA, this article's table of contents (ToC) may be too long – consider shrinking it down by merging short sections or using a proper system of daughter pages as per Summary style.[?]
 * Watch for redundancies that make the article too wordy instead of being crisp and concise. (You may wish to try Tony1's redundancy exercises.)
 * Vague terms of size often are unnecessary and redundant - “some”, “a variety/number/majority of”, “several”, “a few”, “many”, “any”, and “all”. For example, “ All pigs are pink, so we thought of a number of ways to turn them green.”
 * Please ensure that the article has gone through a thorough copyediting so that it exemplifies some of Wikipedia's best work. See also User:Tony1/How to satisfy Criterion 1a.[?]


 * I've tried to address some of the issues above to bring the article along. I've reassessed it as a C class.  I think the biggest issue at this stage is the need for additional references to secondary sources.   Morphh   (talk) 21:30, 28 June 2009 (UTC)

Enterprise restructure
Should we expand/move/? the section on enterprise restructure? As written, it focuses more on non-flow-through entity changes (such as corporate reorganizations). Should there be a partnership aspect? Should it be under sourcing (doesn't thrill me), Individuals vs. enterprises, where? Comments appreciated by tax folks.Sfcardwell (talk) 22:47, 10 March 2010 (UTC)

Map appears to be OR
The map of individual tax systems has no citations or sources listed. While it might be correct, without sources it appears to be WP:OR. I'm not aware of a sufficiently comprehensive single source from which to make or even verify such a map. Comments? Deletion?Oldtaxguy (talk) 01:30, 23 July 2012 (UTC)
 * Agree - needs source if it's to stay. I see you've posted on the user's talk, so we'll wait to hear back.  If we don't have something in a couple days, I'd pull it or we could pull it now and reinsert if sources are provided.   Morphh   (talk) 14:33, 23 July 2012 (UTC)
 * I added the sources on the map's description page. Heitordp (talk) 13:01, 29 July 2012 (UTC)
 * I spot checked some sources, and also checked some other sources. You did not add sources for about 100 countries. The map has inaccuracies, including at least:  Saudi Arabia (inverse of residence system: residents not taxed, nonresidents are), Pitcairn (not a country; population only 67), Akrotiri and Dhekelia (not a country; part of Cyprus), Kiribati (appears to be shown as territorial, but the cite (tax law) indicates residents are taxed on worldwide income.  Also, the mere fact that there are over 70 sources for one map indicates conclusively that it is OR.  If it were accurate, I would applaud your efforts. However, WP is not the place to publish OR. I have deleted. I would note that one of the Big 4 CPA firms has a guide listing only 140 countries. It is the most comprehensive of the books by the Big 4, but still very incomplete.Oldtaxguy (talk) 00:57, 2 August 2012 (UTC)

What do you mean I didn't add sources for about 100 countries? I added sources for all 194 independent countries recognized by the UN, their 40 inhabited dependent territories, plus Taiwan, Kosovo, Palestine, Western Sahara, Northern Cyprus and Somaliland. You can count the number of countries and territories in the list on the map description page, the total is 240. Regarding the supposed inaccuracies:


 * 1. Saudi Arabia taxes the local income of residents who are not citizens of the 6 GCC countries. For residents who are citizens of these countries, there is mandatory zakat instead, which is calculated on net worth and certain kinds of income, in a worldwide basis. I included Saudi Arabia in the residency system because of mandatory zakat. There are a few other exceptional cases: Cuba and the Philippines tax the worldwide income of resident citizens and only local income of resident foreigners, so I included them in the residency system; North Korea does not tax the income of its resident citizens but taxes the worldwide income of resident foreigners, so I included it in the residential system; Andorra does not tax the income of its residents but taxes the local income of nonresidents, so I included it in the territorial system. I'm open to discussion regarding these cases, maybe they can be in a different color on the map.


 * 2. Pitcairn and Akrotiri and Dhekelia are not independent countries, and neither are the other dependent territories, but almost all of them have a taxation system separate from their controlling states. Residents of Pitcairn and of Akrotiri and Dhekelia do not pay income tax to the United Kingdom or to Cyprus. Pitcairn is the permanently inhabited territory with the smallest population, but it is still a separate jurisdiction with its own laws.


 * 3. Kiribati is correctly shown as residency-based (dark blue), maybe you mistook one of the other islands for Kiribati. The islands of Oceania shown as territorial (light blue) are Palau, Micronesia, Marshall Islands, Tuvalu, Tokelau and French Polynesia. The ones shown with no income tax (green) are Nauru, Vanuatu, Wallis and Futuna, Norfolk Island and Pitcairn. The others are shown as residency-based.

The map is accurate according to the sources. If you find any mistakes, let me know and I'll fix them. Many maps in Wikipedia have small mistakes and are constantly being corrected or updated. Small mistakes are not a reason to delete a map completely.

The main source, the guide from Ernst & Young, describes the taxation of 152 countries and territories in detail, including rules for residency, immigration, income tax rates, other taxes, and tax treaties. The map only shows the kind of taxation system used by each country, it's not complex information that requires the study by a financial firm.

I don't think this is OR just because there are 73 sources. The list of countries by population, for example, has a separate source for almost every country. If you think that one of the sources for the map is not reliable and I can't find any other source, I can put the corresponding country as gray (unknown). If anything, at least the 152 countries and territories in the Ernst & Young source should stay. But you can't say that the entire map is OR. Again, I'm open to discussion, and I would like to add the map once the issues are resolved. Heitordp (talk) 07:51, 5 August 2012 (UTC)


 * Since it's been more than a month and no one commented on my response, I readded the map, reorganized the section on taxation systems, and added a table summarizing how all countries and territories tax local and foreign income of individuals, complete with all references. I also added an explanation of citizenship-based taxation with current and past examples.


 * The taxation of corporate income is more complex, as there are various forms of exclusion of foreign income, so I didn't generate a similar table or map for corporations. If anyone more knowledgeable about the subject wants to make an attempt, a good reference to start, covering most countries, is here. Heitordp (talk) 10:39, 9 September 2012 (UTC)

extra space at bottom which needs to be deleted
In ==Notes==.174.3.125.23 (talk) 13:01, 6 December 2014 (UTC)

Assessment comment
Substituted at 19:01, 29 April 2016 (UTC)

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Uruguay
I'm sorry if I upset you. I'll discuss here instead of your user page. As you suggested, I added a reference from the Uruguayan tax authority and clarified that the table applies to all types of income. Heitordp (talk) 04:17, 1 January 2019 (UTC)

Hungary
Shouldn't hungary be listed as a citizenship based system? This is even in one of the sources: — Preceding unsigned comment added by 2A01:36D:2800:2D1A:3CA6:AB13:182D:8A69 (talk) 22:37, 6 July 2018 (UTC)
 * As the sources explain, Hungary adopts citizenship-based taxation in principle but grants two very broad exceptions: it doesn't tax foreign income of its nonresident citizens who also have another nationality or who reside in a country that has a tax treaty with Hungary. More than 99% of nonresident Hungarians satisfy at least the second exception. Heitordp (talk) 22:51, 23 December 2018 (UTC)

Hungary regards all of its citizens as tax residents. The only exception are people holding multiple citizenships AND not having a registered address (temporary or permanent) inside of Hungary. Those to whom a bilateral tax treaty applies, of which Hungary has around 70, are still regarded as tax residents of Hungary. PERIOD. They may on the other hand be entitled to tax relief. To receive tax relief on the basis of a bilateral tax treaty, one must provide a certificate of tax residency, or its equivalent from the other contracting state.

Therefore Hungary applies citizen-based taxation to its own citizens (except to those who have other nationalities and at the same time do not reside in Hungary). The supposition that this law is enforced only rarely is nothing more than that: a baseless and irrelevant idea. The law is clear, Hungary has citizenship-based taxation for its own citizens and territory-based for all others. In addition, all income is taxable, from the very first penny - therefore the law affects any citizen who has had any income and is not a dual citizen living outside of Hungary.

The above is agreed upon by all major consultancy firms, and most importantly, by the law itself. — Preceding unsigned comment added by 211.207.120.167 (talk) 21:50, 23 February 2019 (UTC)
 * According to this source (in Hungarian), directly from the Hungarian tax administration, Hungary does not tax the foreign income of individuals who are considered Hungarian residents under Hungarian law but are considered residents of another country under the terms of a tax treaty. Both the text and the flow chart on page 3 explain it very clearly. This other source (in English) says the same thing. I had added both sources to the Wikipedia article, and they are still there.
 * As you can see, Hungary allows the tax treaties to override Hungarian law, so although such individuals may still be legally considered tax residents of Hungary, Hungary does not tax their foreign income. Hungary may require them to provide a certificate of tax residency from the other country to apply this rule, but it is merely an administrative procedure to confirm that they really satisfy the residency terms of the treaty. Although it may sound like an exception, this relief is actually the general case in practice because more than 99% of nonresident Hungarians live in countries that have tax treaties with Hungary. I find it misleading to show in the article that Hungary imposes citizenship-based taxation in the same way as the US and Eritrea, which don't allow such relief at all. On the contrary, the US specifically adds a clause to all its tax treaties saying that it can still tax its citizens as if the treaty didn't exist. Therefore, I find it more appropriate to list Hungary in the section with countries that apply citizenship-based taxation only in exceptional cases. Do you agree? Heitordp (talk) 02:43, 24 February 2019 (UTC)

I disagree. You are confusing tax treaties with being considered a tax resident. Tax treaties kick in when a person is considered to be a tax resident in either or both of the contracting states. They are still considered residents for tax purposes, but the purpose of the treaty is to define which country will have the right to tax, and to offer relief from double taxation as per the terms of the treaty. Note that the definition of tax residency differs from country to country and treaty to treaty. And once more, this does not change the basic fact that Hungary considers ALL of its nationals (except double citizens with no registered address inside of Hungary) to be tax residents. That they can get relief from paying tax is another matter entirely.

Now on to your so called data point on the treaties applying to 99% of the nationals. I disagree with this having relevance for two reasons:

- First, you could make the same point for the United States. The US has more tax treaties with foreign countries for the avoidance of double taxation, and arguably most US expats would fall under that. Does that change the fact that the US applies citizen-based taxation? NO. Hungary is no different in this regard.

- On the numbers quoted: they are most likely inaccurate. Most Hungarians do not bother with keeping their address up to date, as there is little incentive - especially in cases of non-treaty countries. Only a relatively small administrative penalty could apply for failing to update an address, therefore the incentive is close to non-existent. Because of this, your data very likely does not reflect reality. And even if it did, it wouldn't change the fact that Hungary considers all of its non-dual citizens to be tax residents.

In short, I don't see why you are so insistent on bending the truth in the case of Hungary. As per your standards the US should also be removed from the list of countries that tax based on citizenship. Unless you are willing to remove the US from the list, you have no reason to remove Hungary. — Preceding unsigned comment added by 121.144.47.169 (talk) 19:30, 24 February 2019 (UTC)

The IRS exempts Americans working abroad as long as they make under a certain threshold (google: Foreign Earned Income Exclusion) - in the region of $100,000 a year. This is, as far as I know, irregardless of whether they work in a treaty or non-treaty country. This is what your mentioned treaty clauses apply to. Anything earned above that MAY be taxed, but it is still a very a considerable and generous tax-free allowance. Americans have to file, but not pay anything in most cases. Would you not agree that most expats make less than that? Shouldn't you remove the US from the list then since they only tax people making over 100k a year?

Hungary has NO allowance, and ALL worldwide income from the very first cent is subject to tax - unless as discussed above. This is arguably the harshest law out there, especially if you also take the rate of tax into account.

The bottom line is this: the current wording is an accurate reflection of the legislation in place. If you wish to change it, also remove the US and make note of the Foreign Earned Income Exclusion. I would prefer staying with the facts though, so please kindly leave the article as it is. If possible, please also change the map to reflect the current situation. — Preceding unsigned comment added by 121.144.47.169 (talk) 20:11, 24 February 2019 (UTC)


 * The table in the article is supposed to show whether the country taxes the foreign income of its resident foreigners, resident nationals and nonresident nationals. It should show the final reality, taking into account not only the initial law of each country but also the effect of treaties. If Hungary considers its nonresident nationals as "tax residents" but doesn't tax the foreign income of the overwhelming majority of them, I believe that the table should show "no" in the respective column, or "yes" but at least mention this significant exception in the notes. I find it misleading to not mention the exception at all. The tax treaties of Hungary are not merely a relief or a separate matter, because they override national law changing the fundamental basis of taxation for residents of the treaty country.


 * The same point cannot be said about the US. The US does have tax treaties (which by the way are 66, fewer than the 81 of Hungary), but all of them include a clause saying that the US can still tax its citizens as if the treaty didn't exist. Unlike Hungarians, nonresident US citizens don't get any relief from US tax treaties (with small exceptions regarding some pension plans in a few countries). Instead, their relief comes from the foreign earned income exclusion (which I did mention in the article), which as you wrote is available for all countries regardless of treaties. However, this exclusion only applies to income from work, not to income from investments. So a nonresident US citizen who has a salary lower than $100,000 but earns some interest or dividends is still subject to US taxation on that investment income. Combined with the foreign tax credit, the result is indeed that most nonresident US citizens don't actually owe tax to the US, but according to the IRS, 46% of US citizens who file US income tax returns from abroad do owe at least some US tax. It's a significant portion of these people, and not that much lower than the portion of US residents who owe US income tax (76%).


 * The population data that I cited is not based on notification of address to the country of origin, but on the place of birth recorded in the censuses of the countries of residence, as compiled by the UN. Each country counts in its own census all people living there, regardless of nationality, and asks them where they were born. So for example for Hungary, the data shows the number of people who were counted in the census of each country and said that they were born in Hungary. According to this data, 99% of people who were born in Hungary but were counted in censuses outside of Hungary were in countries that have tax treaties with Hungary. It's true that place of birth is not exactly the same as nationality for every person, but statistically they are practically the same numbers, so it can be concluded that about 99% of Hungarian nationals live in countries that have tax treaties with Hungary. This result is not surprising because such countries cover all of Europe and a very large portion of Asia and the Americas, plus others.


 * There are also a few other countries that tax foreign income of nonresident nationals in exceptional circumstances, as mentioned in the article. For example, Italy, Spain and Portugal tax their nationals living in countries considered tax havens, and France taxes its nationals who move to Monaco. In the case of Hungary, it taxes its nationals living in countries that don't have tax treaties with it. All of these cases represent an extremely small portion of the country's nonresident nationals. Therefore, I find it more appropriate to place Hungary in that group, and misleading to place it in the same group as the US.


 * I also find it misleading to mention the tax rate of Hungary as 33.5%, because this rate includes the payroll taxes, which only apply to local income. The foreign income of a Hungarian (residing in a country without a tax treaty) would be subject by Hungary only to the regular income tax rate of 15%.


 * As a compromise, I propose keeping "yes" in the table for Hungary, but also mentioning the treaty exception in the notes and in the text below the table, as this exception applies to practically all nonresident Hungarians. I also propose grouping Hungary with the US in the text below the table, but also grouping them with the other exceptional countries, in a single list. I also propose removing the map altogether, since the situation is complex. What do you think? Heitordp (talk) 01:13, 26 February 2019 (UTC)
 * As there was no response for many days, I made the changes that I proposed. Heitordp (talk) 04:21, 10 March 2019 (UTC)

Hi,

Yes, there was no response as I considered it case closed. Never in my wildest dreams did I imagine you would come back with another set of non-sensical arguments in order to save face. Let me go through your points again to explain why they are wrong, and why and how your actions are negatively affecting people:

- statistics you quoted are not reliable because most countries affected are third-word countries that have no treaty with Hungary. These will report 0 Hungarians as they simply have no such data available. Do you truly believe that there are 0 Hungarian residents in these countries? That was a wild assumptions there, and one that is entirely wrong. You could easily find Hungarian companies operating in many developing nations just by a simple google search. Even just one such result for a particular country would prove your numbers showing 0 people worthless.

- Consultancy firms such as PWC, Deloitte and others have correctly established the facts. They have also done the same for all the other countries concerned, the ones you recently edited and changed to citizenship-based. There is a big difference though: in those cases citizenship-based taxation is the exemption, while in the case of Hungary, it is the norm. It is not only the law, it is also the practice. Why do you find yourself qualified to go against the option of all these firms and the law itself?

- American editors, who are under the assumption that they are special and need to emphasize this, will most revert your changes. I will not blame them.

- Thee 33.5% tax in Hungary includes healthcare contributions (19.5%), which are compulsory. There are several other taxes and some optional deductions that constitute the de facto income tax. While that nominally is 15%, these additional taxes (contributions) hike it up significantly, making it one of the highest in Europe and the world - only Belgium levies more in Europe. Again, this makes Hungary very very unique, and is therefore worth emphasizing.

And finally, why what you are doing just for your own benefit (to save face) is so harmful: I can tell from the history of the page that the issue of Hungary has been brought up both in the distant and recent past. You kept reverting edits that were based on facts and evidence, because for some reason you decided you know better. The problem is that Hungarian mainstream media have already picked this misleading information up when explaining that in Hungary you are only a tax resident when spending 183 days or more inside the country. Then the original report was quoted by other media outlets. This is clearly false information, and you could indirectly do significant harm to many people by stating inaccurate facts.

If you think the law is not enforced and do happen to speak Hungarian, have a look at the most recent lists published by the national tax agency listing individuals with the largest tax arrears in the past few years. Some of them have no Hungarian address, but judging by their names are Hungarians. Therefore they are most likely Hungarians living abroad.

Again, let's summarize: There are 3 countries enforcing citizenship-based taxation. Eritrea (not sure about the details), Hungary (no allowance, worldwide) and the US (OVER 100k exemption per year in ANY country). The rest would only apply this strategy in extremely limited cases and for a limited period of time - in other words, exceptional ones. In the case of the 3, and especially in the case of Hungary, this is not the case.

What you are doing has an effect on people and is harmful. Please stick to the facts, the way PWC or Deloitte established them. Or the law itself. This article will be changed by Americans, and rightfully so. It is inaccurate. And before it gets reverted back, many people will come to have a look and take what is here for granted. Let's just swallow our pride and go by what the facts are - 3 countries the on principle tax their citizens. No compromise on the facts. Thank you. — Preceding unsigned comment added by 114.111.212.123 (talk) 03:54, 11 March 2019 (UTC)


 * Fine, let's list the countries as classified by the accounting firms. In this case, the US and Hungary have citizenship-based taxation in general, while Finland, France, Italy, Mexico, Portugal, Spain, Sweden and Turkey are exceptional cases. However, I'm not sure about how to list Eritrea and Myanmar. The firms classify Eritrea as territorial taxation and don't even mention the diaspora tax, which is a separate law and has a much lower rate. The firms also describe Myanmar similarly to the US and Hungary, in principle taxing all citizens like residents. Myanmar allows an exemption for foreign salaries of nonresident citizens, similar to the US (but without limit), while still taxing other kinds of income from them. I'm the one who made the observation that the embassies and consulates of Myanmar stopped enforcing this tax in 2012, but it's still in the law, and the accounting firms don't mention the lack of enforcement. So I suppose that it's better to list both Eritrea and Myanmar as general. What do you think?
 * After we agree on the classification, I can also change the map and re-add it to the article. Do you think that it's worth marking the exceptional countries in a different color?
 * I can also re-add the part that you had written about the tax rate and lack of exemption in Hungary. Heitordp (talk) 23:33, 11 March 2019 (UTC)
 * I made these changes. If you still disagree with something, please discuss here. Thanks. Heitordp (talk) 02:13, 17 March 2019 (UTC)

Thank you

Malaysia
Malaysia is no longer a Territorial Tax System since now foreign-source income that has not been taxed at the source is taxable in Malaysia. "The exemption is on condition that the FSI has been subjected to tax “of a similar character to income tax” under the laws of the foreign jurisdiction where the income arose." Source. See this discussion. — Preceding unsigned comment added by IEditWikiToHelp (talk • contribs) 08:46, 10 September 2022 (UTC)