Singapore and the Philippines signed a Development Agenda in 1977. The agreement contains provisions to avoid double taxation of the same source of income. Without a permanent contract, income can be taxed twice, i.e. two countries levy their own taxes on the same income. To address this problem and reduce the overall burden on a taxpayer, Singapore and the Philippines have entered into a DTA that ensures that all income normally taxable in both countries is taxed in only one of them. The provisions of this DTA are explained in more detail below. OECD MODEL TAX TREATIES — See: Model Tax Treaties CRIME, TAX — Tax offences can be defined in tax laws that cover issues such as late filing, late payment, non-reporting of income or taxable transactions, and negligent or fraudulent misrepresentation of tax returns. OFFICE — For the purposes of a tax treaty, the registered office of a company normally constitutes a permanent establishment if the business of that company is carried on in whole or in part through that office. OFFICE AUDIT – An audit in the office of a tax authority, usually a simple tax issue. OFFSHORE BANKING — Offshore banking services consist primarily of borrowing in foreign currencies for non-resident depositors outside the country and passing on foreign currency to other non-residents.
A number of countries have a special system for taxing offshore banks. OFFSHORE COMPANY – a term generally applied to a company registered in a country (often a tax haven) other than the country or countries in which it operates. An offshore company (or non-resident company) is commonly used for captive insurance, overseas marketing, international shipping, and tax exemption regimes. OID — See: Original issue discount OMBUDSMAN — An immediate staff member of the U.S. IRS Commissioner who directs the IRS Problem Solving Program ON CALL SERVICES – Services of a parent company or group service center that are available at all times to members of a multinational enterprise group. ONE HUNDRED AND EIGHTY-THREE (183) DAYS RULE – Being in a country for 183 days or more over a 12-month period can have tax consequences, especially with respect to a person`s tax residency or to tax labor income (although other criteria must also be met). ONSHORE COMPANY – a term sometimes used to refer to the opposite of offshore companies. BURDEN OF PROOF – The burden and responsibility of proving a claim. A principle that is widespread in tax law, for example where the taxable person.B has fundamental responsibility for the declaration of his taxable income or transactions. OPERATING LEASE – A lease in which the lessor is considered the owner of the leased asset for tax purposes. See Leasing Option – A derivative financial instrument, which consists of a fixed agreement that gives a party the right, but not the obligation, to buy or sell property, securities or currencies at a certain future price at a certain future time.
TAXATION OPTION – In the context of VAT, a VAT-exempt operator can sometimes claim to be subject to VAT, the advantage being that he is entitled to his input tax compared to his input tax. COMMON SHARES – Common shares (also known as common shares) are generally shares of equal par value and have the same rights and obligations as the right to participate in the management of the Company by voting at the Annual General Meeting and the right to receive dividends. The rights of ordinary shareholders to dividends are generally subordinated to the rights of bondholders and preferred shareholders. ORIGINAL ISSUE DISCOUNT (OID) – A discount to the face value at the time a bond is issued. The most extreme variant of an OID is a zero-coupon bond, which is originally sold well below its face value and pays no interest until maturity. PRINCIPLE OF ORIGIN – Principle in a VAT regime where goods are taxed in the country where they are produced, i.e. They are taxed on the basis of their place of manufacture or origin. OTHER INCOME – Income that is not otherwise mentioned in a tax treaty is often dealt with in a separate article entitled “Other Income”.
OUTBOUND TRANSACTION – A term that refers to the tax treatment of residents (and possibly citizens) of a country who do business and invest abroad. EXIT TAX – term used in the context of VAT to refer to the tax due on the sale of goods or services by persons subject to the tax and as opposed to input VAT for which a credit note is available. OVERHEAD – The general cost of a business as opposed to the direct cost of producing a good or service. `overheads` means a term which may also be used in tax matters for costs incurred by the registered office of a group for the benefit of branches or subsidiaries. .