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   |per 1000 m3      |NLG 22.40   |
|> 10 mln. m3                       |per 1000 m3      |NLG 14.60   |


Exemptions
All usage other than as fuel is exempt.


7.2. Tax on groundwater

Groundwater tax is levied on the extraction of sweet groundwater. This tax
has been levied since 1 January 1995. The tax revenue is estimated at
approximately NLG 360 million for 2000.
Taxable persons
The tax is levied on the proprietors of the establishments extracting
groundwater. These are, for example, the manufacturers of drinking water,
farmers, and industries that use groundwater.
Rates
For drinking water companies the rate is NLG 0.3530 per mі; for others the
rate is NLG 0.2634 per mі. Rebates are applied for infiltrated water.
Exemptions
Exemptions are applicable under certain conditions, for example in case of
extraction of groundwater for draining a building site, as well as test-
extractions, extraction for use for sprinkling and irrigating land and
extraction needed to clean groundwater.


7.3. Tax on tap water

The tax on tap water is levied on the deliverance of tap water to a maximum
300 cubic meters per year. The tax revenue is estimated at NLG 215 million
for 2000.
Taxable persons
The tax is levied on the tap watercompanies.
Rates
The rate is NLG 0.285 per mі.


7.4. Tax on tap water

The tax on tap water is levied on the deliverance of tap water to a maximum
300 cubic meters per year. The tax revenue is estimated at NLG 215 million
for 2000.
Taxable persons
The tax is levied on the tap watercompanies.
Rates
The rate is NLG 0.285 per mі.


7.5. Regulatory energy tax

The regulatory energy tax is levied on the consumption of natural gas,
electricity and mineral oil products when used as substitutes for gas by
domestic users or commercial establishments. The tax revenue is estimated
at NLG 4,208 million for 2000. The revenues are returned to domestic users
and business by way of reductions in other taxes.
Taxable persons
The tax is levied on the energy distribution companies and manufacturers
and wholesalers of mineral oils. These companies pass on the tax to their
customers.
Rates
Natural gas is taxed to a maximum of 1.000.000 cubic metres per year, with
a tax-free allowance of 800 cubic metres per year. Electricity is taxed to
a maximum of 10.000.000 kWh per year, with a tax-free allowance of 800 kWh.
The rates for 2000 are as follows:
|fuel                |unit           |cents per|         |
|                    |               |unit     |         |
|                    |               |         |2000     |
|Natural gas         |cubic metre    |         |20.82    |
|Electricity         |kWh            |         |8.20     |
|Light fuel oil      |litre          |         |17.43    |
|Heating oil         |litre          |         |17.56    |
|LPG                 |kg             |         |20.78    |


A zero rate applies for fuels used for transport purposes.
Exemptions
Exemptions are for instance applicable for all usage other than as fuel and
for natural gas used to produce electricity.


7.6. Tax on uranium
This tax is levied on uranium-235. The tax was introduced so that nuclear-
generated electricity would be taxed in the same way as fuel-based
electricity. The tax came into force on 1 january 1997. The tax revenue has
been estimated initially at NLG 12 million for 2000.
Taxable persons
This tax is due by nuclear energy companies.
Rates
NLG 33.17 per gram of Uranium-235.


          8. Избежание двойного налогообложения на доход, прибыль и
   богатство(Avoidance of Double Taxation for Taxes on Income, Profits and
                                   Wealth)



8.1. General

The Netherlands has two kinds of arrangements for the avoidance of double
taxation for taxes on income, profits and net wealth, and for inheritance
and gift tax. It has concluded conventions for the avoidance of double
taxation with a large number of countries (see 8.3). If no convention is
applicable then the unilateral provisions as laid down in the 1989 Double
Taxation (Avoidance) Decree of the Netherlands are applicable (see 8.4.).
The double taxation conventions apply for residents of the Netherlands and
for residents of the treaty countries. The above mentioned Decree applies
for residents of the Netherlands, and for residents of the treaty
countries. The above mentioned Decree applies only for residents of the
Netherlands.


8.2. Methods

The Dutch tax system provides for three different methods for avoiding
double taxation on income from foreign sources. Double taxation is avoided
by means of the exemption with progression method, the credit method, or
deduction of foreign taxes as costs. These methods are used under the
Decree and, with only a few exceptions, under the double taxation
conventions.


8.2.1. The exemption with progression method

The exemption with progression method is usually used for income tax,
corporation tax and wealth tax. In principle relief is provided for
positive and negative items of income from foreign sources, on a per
country basis. The exemption method involves a reduction of the Dutch tax
on total income. The reduction is calculated as follows:
|foreign  |x total Dutch tax due on total taxable income                |
|income   |                                                             |
|Total    |                                                             |
|income   |                                                             |


(foreign income divided by total income; multiply result by the total Dutch
tax due on total taxable income)
If the income from foreign sources exceeds the total income then no full
relief for foreign taxes is provided in the year concerned. In such cases
relief is provided in the subsequent years.
Foreign losses reduce the Dutch tax base in the year in which they arise as
they are offset against the domestic income. However any losses from abroad
which are incurred in the preceding years are deducted from the foreign
income before relief is granted.


8.2.2. The credit method

The credit against tax method, or credit method, is usually used for
foreign withholding taxes on investment income such as dividends, interest
and royalties, on a per country basis (a ministerial order concerning the
possibility of choosing between the credit method on a per country basis
and the credit method on an overall basis is in preparation). The tax
reduction amounts to the lower of the foreign withholding tax or the Dutch
tax attributable to the foreign dividends, interest and royalties.
Since the foreign withholding taxes for which credit is allowed are usually
levied on a gross basis, whilst Dutch income tax is levied on a net basis,
it is quite possible that the Dutch tax attributable to the relevant items
of income is not sufficient to provide full credit for the tax levied by
the source country. In such cases the excess foreign taxes may be carried
forward to subsequent years.
Since January 1, 1999 in a few conventions for the avoidance of double
taxation the credit method is also applicable for income from passive
investments derived through a permanent establishment (see 8.4.2).


8.2.3. Deduction as costs

In situations in which no exemption or credit is allowed then any foreign
taxes paid may be deducted as costs related to the relevant income. In
situations in which a tax credit would normally be used then the taxpayer
may opt for non-recognition of the tax credit. This option is applicable to
the year in which the income is received and to the total amount of all
dividends, royalties and interest received in that year. The option will
thus result in a deduction of foreign taxes as costs.
 

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