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Implications 李亭 高娟娟 袁帥 孫璐 Differences and Similarities Implication Differences and Similarities Contents Taxation System Tax jurisdiction Scope of taxation Ine tax rate Tax Credits Taxation System ? Both UK and US are based on the prehensive ine tax base ? Advantages of prehensive ine tax They both utilize domiciliary jurisdiction And source jurisdiction. In US, tax obligation is also based on citizenship Add your text Add your text Tax jurisdiction similarity difference Scope of taxation the gross ine includes earned ine, capital ine and transfer ine. the putation of taxable ine and ine tax liability Include Ine tax putation, personal allowances and gift aid. Ine tax