The International Tax Law Concept of Dividend, 2nd Edition

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The International Tax Law Concept of Dividend, 2nd Edition

By Marjaana Helminen
Kluwer Law International June 2017

Specifications

ISBN-13
9789041183941
Publisher
Kluwer Law International
Publication
June 2017
Format
Hardback , 304 pages
Jurisdiction
International ? Countri(es) for reference only

Details

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 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 states’ 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.

Table of Contents

§         Tax Treatment of the Inter-corporate Cross-Border Dividends
§         Interaction among Different Legal Systems of International Tax Law
§         Different Dividend Concepts in International Tax Law
§         Dividend-Distributing Entities
§         Dividend-Stripping and the Dividend-Generating Relationship
§         Fictive Distributions as a Dividend
§         Classification of Economic Benefits from Corporations to their Shareholders in the Form of Transfer Prices
§         Classification of Return on Debt-Equity Hybrids
§         Classification of Interest in Thin Capitalization Situations
§         Classification of Liquidation Distributions

 

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