Dividends Under The Income Tax
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Dividends Under The Income Tax
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Author : Daniel Mark Holland
language : en
Publisher:
Release Date : 1962
Dividends Under The Income Tax written by Daniel Mark Holland and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1962 with Business & Economics 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 : 2010-01-01
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 2010-01-01 with Law categories.
The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. 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. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the classification of various inter-corporate transactions, including: and Payments made under dividend-stripping arrangements. and Fictitious profit distributions. and Economic benefits in the context of transfer pricing. and Returns on debt-equity hybrids. and 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. The approaches adopted in different statesand national tax law are covered by a more general analysis. The comprehensive coverage and practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
Corporation Profits And Dividends Under The Income Tax Act
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Author : Association canadienne d'études fiscales
language : en
Publisher:
Release Date : 1949
Corporation Profits And Dividends Under The Income Tax Act written by Association canadienne d'études fiscales and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1949 with categories.
Corporation Profits And Dividends Under The Income Tax Act
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Author : Canadian Tax Foundation
language : en
Publisher:
Release Date : 1949
Corporation Profits And Dividends Under The Income Tax Act written by Canadian Tax Foundation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1949 with Taxation categories.
The Taxation Under The Income Tax Act Of The Interest And Dividends On Non Residents
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Author : Paul Ferdinand Ferreira
language : en
Publisher:
Release Date : 1988
The Taxation Under The Income Tax Act Of The Interest And Dividends On Non Residents written by Paul Ferdinand Ferreira and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1988 with categories.
The Dividend Concept In International Tax Law Dividend Payments Between Corporate Entities
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Author : Marjaana Helminen
language : en
Publisher: Springer
Release Date : 1999-12-09
The Dividend Concept In International Tax Law Dividend Payments Between Corporate Entities written by Marjaana Helminen and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999-12-09 with Business & Economics categories.
The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. 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. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the 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 capitalisation situations and distributions following liquidation The analysis of each transaction refers to international tax law, including tax treaties, European tax law and the domestic tax law of Finland, Germany, Sweden and the United States. The comprehensive coverage and practical nature of The Dividend Concept in International Tax Law make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
The Taxation Under The Income Tax Act Of The Interest And Dividends Of Non Residents
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Author : Paul Ferreira
language : en
Publisher:
Release Date : 1986
The Taxation Under The Income Tax Act Of The Interest And Dividends Of Non Residents written by Paul Ferreira and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1986 with Dividends categories.
The Economic Effects Of Dividend Taxation
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Author : Kenneth James McKenzie
language : en
Publisher: The Committee
Release Date : 1996
The Economic Effects Of Dividend Taxation written by Kenneth James McKenzie and has been published by The Committee this book supported file pdf, txt, epub, kindle and other format this book has been release on 1996 with Corporations categories.
The Definition Of Dividends Under The Income Tax Act 1976
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Author :
language : en
Publisher:
Release Date : 1990
The Definition Of Dividends Under The Income Tax Act 1976 written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990 with categories.