Free PDF BookThe Dividend Concept in International Tax Law Dividend Payments (Series on International Taxation)

Download The Dividend Concept in International Tax Law Dividend Payments (Series on International Taxation)

Download The Dividend Concept in International Tax Law Dividend Payments (Series on International Taxation)

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Book Details :
Published on: 1970-12-01
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Original language: English

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. TR 2001/13 - Income tax: Interpreting Australia's Double ... Commissioner of Taxation. 19 December 2001 Footnotes. The Taipei Agreement (Schedule 41 to the International Tax Agreements Act 1953) is a special case and is ... TR 97/20 - Income tax: arm's length transfer pricing ... Taxation Ruling TR 97/20 Income tax: arm's length transfer pricing methodologies for international dealings Insights KPMG CA Insights Insights. Welcome to the KPMG knowledge base of research that demonstrates our understanding of complex business challenges faced by companies around the world. Income tax - Wikipedia An income tax is a tax imposed on individuals or entities (taxpayers) that varies with the income or profits (taxable income) of the taxpayer. Details vary widely by ... Practical Law A Q&A guide to private client law in Mexico. The Q&A gives a high level overview of tax; tax residence; inheritance tax; buying property; wills and estate management ... PwC HK: China Tax/Business News Flash 2016 : Dec 2016: Issue 40 : China introduces the first green tax law for environmental protection : Dec 2016: Issue 39 Georgism - Wikipedia Georgism also called geoism and single tax (archaic) is an economic philosophy holding that while people should own the value they produce themselves economic ... Commentary on Typical Provisions of Irish Tax Treaties Commentary on Typical Provisions of Irish Tax Treaties The following is a general commentary on the various articles found in typical Irish double tax treaties that ... NYSSCPA The New York State Society of CPAs NYSSCPA is the premier professional association for CPAs (certified public accountants) in New York State. Budget 2016: Tax Measures: Supplementary Information Overview. This volume provides detailed information on each of the tax measures proposed in Budget 2016. Table 1 lists these measures and provides estimates of their ...
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