PASSIVE INCOME - Taxand
PASSIVE INCOME
PRESENTATION BY RAHUL CHARKHA
July 31, 2019
OUTLINE
1. Active vs Passive income 2. Dividends 3. Interest 4. Royalties
5. Concept of beneficial ownership
6. Attribution of taxing rights ? a synopsis
ACTIVE vs PASSIVE INCOME
ACTIVE vs PASSIVE INCOME
Capital employed Equity Debt
Permission to use assets Purchase with subsequent disposal
Activities Employment
Passive incomes Dividends Interest Royalties
Capital gains Active incomes Dependent personnel service
Professional service
Independent personnel service
ARTICLE 10 DIVIDENDS
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