Traduction de «Impôt sur le revenu et les bénéfices nets » (Français → Anglais) :

taxes on net income and profits

income,profit,and capital gains taxes-% of total taxes

income,profit,and capital gains taxes-% of current revenue

Canada-Manitoba Income Tax Collection Agreement

corporate income tax | corporate tax | corporation income tax | corporation tax | profits tax | tax on profits

corporate income tax [ corporation income tax | corporation tax | corporate tax ]

corporate income tax | corporation income tax | income tax

after-tax profits [ aftertax profits | profits after tax ]

distribution of net operating income

net operating profit after taxes | net operating profit after tax | after-tax operating profit [ NOPAT ]

(a) where, pursuant to the income tax law of the country in which a particular foreign affiliate is resident, the particular affiliate and one or more other corporations, each of which is resident in that country, determine their liabilities for income or profits tax payable to the government of that country for a taxation year on a consolidated or combined basis, any amount paid by the particular affiliate to any of the other corporations to the extent that it may reasonably be regarded as being in respect of income or profits tax that would otherwise have been payable by the particular affiliate in respect of a particular amount includ ...[+++]ed in computing the taxpayer’s income by virtue of subsection 91(1) of the Act for a taxation year in respect of the particular affiliate, had the tax liability of the particular affiliate and the other corporations not been determined on a consolidated or combined basis, is hereby prescribed to be foreign accrual tax applicable to the particular amount; and

(b) where, pursuant to the income tax law of the country in which a particular foreign affiliate of a taxpayer is resident, the particular affiliate, in computing its income or profits subject to tax in that country for a taxation year, deducts an amount in respect of a loss of another corporation resident in that country, any amount paid by the particular affiliate to the other corporation to the extent that it may reasonably be regarded as being in respect of income or profits tax that would otherwise have been payable by the particular affiliate in respect of a particular amount included in computing the taxpayer’s income by virtue of ...[+++] subsection 91(1) of the Act for a taxation year in respect of the particular affiliate, had the tax liability of the particular affiliate been determined without deducting the loss of the other corporation, is hereby prescribed to be foreign accrual tax applicable to the particular amount.

(i) any such income or profits tax paid by the primary affiliate for the year shall be deemed not to have been paid and any refund to the primary affiliate of income or profits tax otherwise payable by it for the year shall be deemed not to have been made,

(A) to the extent that such income or profits tax would otherwise have reduced the net earnings included in the exempt earnings of the secondary affiliate, be deducted from the exempt surplus or added to the exempt deficit, as the case may be, of the primary affiliate,