While the five pillars of co-operative compliance 1 that were set out in the 2008 report have been maintained, the report sets out how the new framework for co-operative compliance will now incorporate a more systematic approach to tax risk, based upon the important concept of a Tax Control Framework that is followed by each business taxpayer. The OECD believes that the presence of such a tax control framework will allow more objective and justified criteria to be applied as part of the relationship between taxpayer and tax authority.
UNCONTROLLED TRANSACTION -- Transaction between independent and unrelated enterprises.
UNDER-CAPITALISATION -- See: Thin capitalisation
UNDERLYING TAX -- Tax which is charged on corporate income out of which dividends are paid, but which does not appear as a direct deduction or withholding from the dividend itself.
UNDERLYING TAX CREDIT -- See: Credit, underlying tax
UNDISTRIBUTED PROFITS TAX -- Annual tax imposed, in addition to the normal corporate income tax, on the undistributed portion of the profits or surplus of a corporation.
UNDUE HARDSHIP -- A substantial financial loss that would result to a taxpayer from making payment on the due date of the amount of taxes with respect to which the extension is desired. Undue hardship is a condition precedent to the granting of an extension of time to make a tax payment.
UNEARNED INCOME -- Term used to describe investment income such as dividends, interest and royalties.
UNILATERAL RELIEF -- Granting of relief from the effects of international double taxation on the basis of domestic legislation rather than the provisions of a tax treaty.
UNIMPROVED PROPERTY -- Land that has received no development, construction, or site preparation (. raw land).
UNITARY TAX SYSTEM -- Under a unitary tax system, the profits of the various branches of an enterprise or the various corporations of a group are calculated as if the entire group is a unity. A formula is used to apportion the net income of the whole group to the various parts of the group. Usually a combination of property, payroll, turnover, capital invested, manufacturing costs, etc. are formula factors.
UNLIMITED LIABILITY -- Liability of an investor which extends to the full extent of his personal assets, as in the case of a sole proprietor or general partner.
UPSTREAM DIVIDEND -- Dividends flowing from a subsidiary company to its parent company.
USEFUL LIFE -- Period during which it is estimated that a depreciable asset will provide useful service to the business in which it is used.
USE TAX -- Tax on goods which are used within the taxing jurisdiction although the goods were purchased in another jurisdiction