MAINTENANCE COSTS — 1. Expenses incurred by a taxpayer to support his or her family, former spouse or other family members. 2. The costs of maintaining or maintaining a building or equipment. MISCONDUCT – Inappropriate or immoral conduct by a professional in the performance of his or her duties, intentionally or through negligence or ignorance; Often applied to accountants, accountants and lawyers to denote the careless or clumsy execution of tasks where professional skills are mandatory. MANAGEMENT, PLACE OF — See: Seat of management MANAGEMENT, PLACE OF ACTUAL MANAGEMENT — See: Place of effective management ADMINISTRATIVE EXPENSES — In general, administrative expenses are deductible in order to generate the taxable profits of a business carrying on a business. In the case of a group of companies, it may be important to decide to what extent the general costs of managing the group are to be invoiced and reimbursed by the members of the group. ADMINISTRATIVE FEE – Generally, fees or charges for management and/or administrative services provided by a parent company or head office. MANAGEMENT SERVICE — See: MAP intra-group services — See: MAP APA mutual agreement procedure — See: BAPA MARGINAL TAX OF TAX — The tax rate applicable to the top or upper range of income or other taxable income of a taxpayer when the corresponding tax is levied on those items at graduated rates. NEGOTIABLE SECURITIES — See: Listed securities INTANGIBLE MARKETING — An intangible asset that deals with marketing activities that contribute to the commercial exploitation of a product or service and/or have a significant advertising value for that product. MARK-TO-MARKET – A tax and/or accounting agreement under which the value of assets/liabilities is adjusted to reflect the fair value at a given point in time. MARK-up – An increase in the price of something, especially the price a merchant pays for something, to the price at which they sell it.
In the transfer pricing context, one method of estimating an arm`s length price for transactions between associated companies is to increase the supplier`s costs through a reasonable mark-up (cost-plus method). MEMORANDUM OF UNDERSTANDING (MOU) — Under a tax treaty, a document exchanged between the parties setting out the parties` agreement to the agreement. Usually, this does not have contract status, but the status depends on the document itself. MERGER – A term commonly used to describe a set of transactions involving the reorganization of companies. MINING ROYALTIES – Periodic payments, generally based on the quantity or price of minerals extracted, made by mining companies to nation states or other owners of mineral resources in exchange for the right to exploit certain mineral resources. MINIMUM TAX – In some countries, companies are still subject to a certain annual tax, whether or not they have made a profit. MINISTRY OF FINANCE (MOF) — A GOVERNMENT DEPARTMENT GENERALLY RESPONSIBLE FOR FORMULATING MONETARY POLICY, ENFORCING TAX LAWS, COLLECTING REVENUE, ETC. MIXED CORPORATION – a term used to refer to an intermediary holding company whose purpose is to „blend” income from various foreign sources in order to maximize the usefulness of foreign tax credits.
The blending company receives income from both countries with a higher tax rate than the destination country and from countries with a lower tax rate, which it then distributes as dividends. This structure has the effect of averaging the rate of foreign taxes paid. IMC — Abbreviation for multinational corporation MNE — Abbreviation for multinational corporations MODEL TAX TREATY (TREATIES) — A Model tax treaty is designed to streamline and standardize the division of tax laws between countries in cross-border situations. The OECD and UN Model Tax Treaties are widely used, and a number of countries have their own model tax treaties. MORTGAGE – A written instrument that creates a lien on real estate as collateral for the payment of a specific debt. MORTGAGE TAX – A tax on mortgages, usually in the form of stamp duty, that is levied on the mortgage document. MOTIF TEST – Test commonly found in tax regulations designed to prevent tax avoidance. For example, the rules may provide that certain consequences follow if the single, principal or principal purpose of a particular transaction is the tax reduction. Memorandum of Understanding — See: Memorandum of Understanding MULTINATIONAL ENTERPRISES (MNES) — A company or group of companies operating in two or more countries.