Análisis del Offshore trust en la imposición sobre la renta

Identificador:  TDX:4084

Handle: https://hdl.handle.net/20.500.11797/TDX4084

Autors:  Ester Lea, Patty Guisbert

Resum:
The offshore trust is a legal vehicle with the possibility of deferring the distribution of income and suspending the payment of income tax, or relocating the tax bases to obtain tax benefits, or reducing income tax, or being excluded from paying it. , due to the non-recognition or ignorance of the legislation or the jurisprudence of continental law jurisdictions, and therefore, there is a need for an equitable and uniform tax treatment for offshore trusts that overcomes the difficulties encountered in their control, as well as, improve the progress made in terms of information exchange in recent years, so it is proposed to apply tax harmonization based on legal comparison, as it is the theory that best suits the current needs of the international tax context, through the application of the interpreted and systematized procedure in the research work from the Neumark report.