Author : Roland Dahlman
Publisher :
ISBN 13 : 9789185445349
Total Pages : 0 pages
Book Rating : 4.4/5 (453 download)
Book Synopsis Corporate Form and International Taxation of Box Corporations by : Roland Dahlman
Download or read book Corporate Form and International Taxation of Box Corporations written by Roland Dahlman and published by . This book was released on 2006 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: A foreign subsidiary indirectly owned in a third country jurisdiction is in this thesis classified as a Box. The subject of the thesis is primarily to analyse and establish the following connections: the intended corporate objectives and ends and the modus operandi and the means that often require the Box Corporation as a necessary vehicle to attain those ends. The close connections between corporate law and tax law as intended legal results interdependent on one another. The application of the Box Corporation as an important vehicle for international tax planning by Swedish corporate groups on ever increasing competitive international markets and the special tax problems connected to the Box Corporation as it presents serious challenges to the pursuits for a consistent, neutral and undistorted Swedish corporate tax system. The thesis also investigates legislative and regulatory public reactions to the Box Corporation in the ways of controlled foreign corporation (CFC) tax provisions, of denying tax treaty privileges by limitation on benefits clauses and of increasing domestic requirements on reportable transactions and international exchange of information and co-operation. The thesis analyses resulting tensions, in effect, between predictable legal results by literal interpretation of law based on form and economic realities based on substance as fundamental matters of tax policy.