Dividend Tax Abuse
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Dividend Tax Abuse
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Author : United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations
language : en
Publisher:
Release Date : 2008
Dividend Tax Abuse written by United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Dividends categories.
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2012
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law written by Guglielmo Maisto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Corporations categories.
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
The International Tax Law Concept Of Dividend
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Author : Marjaana Helminen
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2017-05-02
The International Tax Law Concept Of Dividend written by Marjaana Helminen and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-05-02 with Law categories.
The distribution of profits between corporations resident in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. The OECD BEPS project has only increased the relevance. This unique work discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The author examines the tax classification of various inter-corporate transactions, including: – Payments made under dividend-stripping arrangements. – Fictitious profit distributions. – Economic benefits in the context of transfer pricing. – Returns on debt-equity hybrids. – Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the BEPS development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Tax Avoidance Dividend Signaling And Shareholder Taxation In An Open Economy
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Author : Richard Löfqvist
language : en
Publisher: Department of Economics Uppsala University
Release Date : 2001-01-01
Tax Avoidance Dividend Signaling And Shareholder Taxation In An Open Economy written by Richard Löfqvist and has been published by Department of Economics Uppsala University this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001-01-01 with Dividends categories.
Fighting Tax Crime The Ten Global Principles Second Edition
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2021-06-17
Fighting Tax Crime The Ten Global Principles Second Edition written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-17 with categories.
First published in 2017, Fighting Tax Crime - The Ten Global Principles is the first comprehensive guide to fighting tax crimes. It sets out ten essential principles covering the legal, institutional, administrative, and operational aspects necessary for developing an efficient and effective system for identifying, investigating and prosecuting tax crimes, while respecting the rights of accused taxpayers.
Comparison Of Us Uk And German Corporate Income Tax Systems With Respect To Dividend Relief
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Author : Benjamin Mahr
language : en
Publisher: GRIN Verlag
Release Date : 2004-08-12
Comparison Of Us Uk And German Corporate Income Tax Systems With Respect To Dividend Relief written by Benjamin Mahr and has been published by GRIN Verlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004-08-12 with Business & Economics categories.
Essay from the year 2004 in the subject Business economics - Accounting and Taxes, grade: Distinction (83%), The University of Sydney (Faculty of Law), course: Comparative Corporate Taxation, language: English, abstract: This essay briefly describes the main different theoretical approaches (tax systems) designed to alleviate the double burden of corporation tax and shareholder income tax under Part 2. Parts 3- 5 explain how the problem of dividend double taxation was tried to be solved in the heterogeneous tax systems of the Germany, the UK and the US. However, the essay will not cover the different double tax avoiding treaties in force in those countries.
Streaming And Refundability Of Imputation Credits
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Author : Policy Advice Division, Inland Revenue, New Zealand
language : en
Publisher: Policy and Strategy, Inland Revenue, New Zealand
Release Date : 2008-08-14
Streaming And Refundability Of Imputation Credits written by Policy Advice Division, Inland Revenue, New Zealand and has been published by Policy and Strategy, Inland Revenue, New Zealand this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-08-14 with Dividends categories.
Corporate Shareholder Income Taxation And Allocating Taxing Rights Between Countries
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Author : Peter Andrew Harris
language : en
Publisher:
Release Date : 1996
Corporate Shareholder Income Taxation And Allocating Taxing Rights Between Countries written by Peter Andrew Harris and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1996 with Law categories.
This ground-breaking book from the IBFD proposes a fundamental change to the norms for the allocation of taxing rights among countries. The author uses an in-depth study of imputation systems to expose the flaws in the current international order, arguing that it is theoretically unsound. He then develops an alternative that would resolve many of the problems presented by international tax law today. Imputation systems are founded on a philosophy that corporations are not appropriate subjects of income taxation, other than as vehicles for the collection of tax, & they accordingly seek to alleviate economic double taxation. In practice they do not achieve this aim. In a domestic context, considered in the first four chapters, their inconsistencies & inaccuracies obscure the more fundamental flaws of the income taxation systems of which they form a part. In an international context, considered in the second four chapters, the difficulties associated with imputation systems highlight the deficiencies in current norms for the allocation of taxing rights among countries. The author examines those norms & finds them an inadequate basis for the international order. The alternatives he proposes would place the international taxing order on a firm theoretical footing & could be applied to any type of corporate tax system. If adopted, his proposals would obviate the need for much current international tax law. Treaties, measures for the avoidance of double taxation & many anti-avoidance measures would become superfluous. This extremely important book, based on prize-winning doctoral research, is destined to become a classic in the field. The acute perception & explication of theories underpinning international taxation make it essential reading.
The Improper Use Of Tax Treaties With Particular Reference To The Netherlands And The United States
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Author : Stef Weeghel
language : en
Publisher: Kluwer Law International B.V.
Release Date : 1998-03-27
The Improper Use Of Tax Treaties With Particular Reference To The Netherlands And The United States written by Stef Weeghel and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998-03-27 with Business & Economics categories.
"With particular reference to the Netherlands and the United States."--T.p.
Stripping Of Corporate Surplus
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Author : Canada. Royal Commission on Taxation
language : en
Publisher:
Release Date : 1967
Stripping Of Corporate Surplus written by Canada. Royal Commission on Taxation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1967 with Corporations categories.