The Dividend Concept In International Tax Law Dividend Payments Between Corporate Entities
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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 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.
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.
Corporate Tax Law
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Author : Peter Harris
language : en
Publisher: Cambridge University Press
Release Date : 2013-03-07
Corporate Tax Law written by Peter Harris and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-03-07 with Law categories.
A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.
The Taxation Of Corporations And Shareholders
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Author : Martin Norr
language : en
Publisher: Springer Science & Business Media
Release Date : 2013-06-29
The Taxation Of Corporations And Shareholders written by Martin Norr and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-06-29 with Business & Economics categories.
This monograph is principally the work of the late Martin Norr. He completed a draft of the entire monograph but had not yet revised it when he died in late 1972. At that time, the integration of corporate and shareholder taxation was just beginning to become of widespread interest in the United States. With the increasing interest thereafter, the International Tax Program began to revise his manuscript, making as few changes as possible in the original draft. We had the benefit of criticism and analysis from Professor Richard M. Bird of the University of Toronto, now Director of the Institute of Policy Analysis there. In addition, Mr. Mitsuo Sato of the Ministry of Finance in Japan gave freely of his time in carefully suggesting changes throughout the manuscript. The present version of Chapter 3 owes a great deal to his additions and suggestions. Thanks are also due to Professor Hugh J. Ault of Boston College Law School for the Appendix, containing his description of the German integration system that became effective in 1977, which was first published in Law & Policy in International Business. Mr. Norr's interest in the subject of corporate and shareholder taxation developed while he was writing the International Tax Program's World Tax Series volume Taxation in France, published in 1966. The integration of French taxes on corporations and shareholders took place just after that volume was finished, but had been under discussion in France for some time before then.
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 Aktieskatter 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 Integration Of Corporate And Personal Taxes In Europe
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Author : Michael P. Devereux
language : en
Publisher: The Committee
Release Date : 1997
The Integration Of Corporate And Personal Taxes In Europe written by Michael P. Devereux and has been published by The Committee this book supported file pdf, txt, epub, kindle and other format this book has been release on 1997 with Business tax categories.
The paper describes in some detail the imputation systems in France, Germany, Italy and the United Kingdom, paying particular attention to the minimum tax. It also briefly addresses a number of economic issues; it examines the likely impact of the minimum tax on the investment and financing decisions of companies, and outlines how the impact of the imputation system depends on the minimum tax; and it also briefly raises the issue of alternative forms of taxation of corporate source income.
International Tax Policy And Double Tax Treaties
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Author : Kevin Holmes
language : en
Publisher: IBFD
Release Date : 2007
International Tax Policy And Double Tax Treaties written by Kevin Holmes and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Double taxation categories.
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Luxembourg In International Tax
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Author : Marc Schmitz
language : en
Publisher:
Release Date : 2015
Luxembourg In International Tax written by Marc Schmitz and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with categories.
Switzerland In International Tax Law
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Author : Xavier Oberson
language : en
Publisher: IBFD
Release Date : 2011
Switzerland In International Tax Law written by Xavier Oberson and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Double taxation categories.
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).