• Income Tax Issues Arising from Cross Border Employee Stock Options. What tax issues to be concerned by employees and employer setting up cross-border

Publisher:
Lambert Academic Publishing
Publication date:
2010-09-28
Authors:

(Nova Triana Tarigan SE Ak,LLM is tax director at Telkomsel,the biggest telecommunication group in Indonesia. Previously She has working as tax advisor in big four accounting firm in Jakarta for almost 6 years before continues studying at the International Tax Program at Faculty of Law of Leiden University, the Netherlands.)
ISBN:
9783843352994

Description:

Tax Burden!Deterioration of the tax compliance!Tax Deferral Advantegeous! Most wanted global compensation form! These are main issues when started the research for the book. The book is based on the Adv LLM paper by the author submitted in fulfillment of requirements of the Adv LLM in International Tax Law Degree at the International Tax Center Leiden (Leiden University) with supervision of Dr Pasquale Pistone The book brings about an increased awareness of fiscal importance in setting up an employess stock options plans. Explaining briefly the tax considerations of every type of stock option plans including timing of taxation that varies across countries and various characterization of it under each domestic laws of countries have specific tax regulations for it and those do not have such tax regulations. The research concludes that possible solutions for the problem of international double taxation may be done through clarifying the commentaries on article 15, 13(4) and artcile 23 of OECD Model tax Convention as it has been done by the working party of cross border employee stock option plans.

MATERIAS: international taxation, tax on stock option, chracterization, tax treaty, American Options, European Options, ESOP, multiple residence taxation, statutory options, timing mismatch, option values