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Dividend Taxation In Europe
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Book Synopsis Taxation of Intercompany Dividends Under Tax Treaties and EU Law by : Guglielmo Maisto
Download or read book Taxation of Intercompany Dividends Under Tax Treaties and EU Law written by Guglielmo Maisto and published by IBFD. This book was released on 2012 with total page 1093 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective by : Erwin Nijkeuter
Download or read book Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective written by Erwin Nijkeuter and published by Kluwer Law International B.V.. This book was released on 2012-08-01 with total page 168 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.
Book Synopsis The Integration of Corporate and Personal Taxes in Europe by : Michael P. Devereux
Download or read book The Integration of Corporate and Personal Taxes in Europe written by Michael P. Devereux and published by The Committee. This book was released on 1997 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Dividend Taxation in Europe by : Alvin C. Warren
Download or read book Dividend Taxation in Europe written by Alvin C. Warren and published by . This book was released on 2009 with total page 55 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article analyzes a complex line of recent decisions in which the European Court of Justice has set forth its vision of a nondiscriminatory system for taxing corporate income distributed as dividends within the European Union. We begin by identifying the principal tax policy issues that arise in constructing a system for taxing cross-border dividends and then review the standard solutions found in national legislation and international tax treaties. Against that background, we examine in detail a dozen of the Court's decisions, half of which have been handed down since 2006. Our conclusion is that the ECJ is applying a standard of nondiscrimination to evaluate national tax laws in a manner totally divorced from the underlying tax policy norms that produced the legislation at issue. Some, but not all, of the decisions seem to require nondiscrimination based on the destination, but not the origin, of corporate investment. The result is a jurisprudence that fails to hold together substantively, functionally, and rhetorically. In many instances, this result follows from largely formalistic distinctions made by the Court, such as whether a withholding tax on dividends should be considered corporate or shareholder taxation.
Book Synopsis Taxation of Investment Funds in the European Union by : Tomi Viitala
Download or read book Taxation of Investment Funds in the European Union written by Tomi Viitala and published by IBFD. This book was released on 2005 with total page 427 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.
Book Synopsis The International Tax Law Concept of Dividend by : Marjaana Helminen
Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis The Taxation of Patent Royalties, Dividends, Interest in Europe by : International Bureau of Fiscal Documentation
Download or read book The Taxation of Patent Royalties, Dividends, Interest in Europe written by International Bureau of Fiscal Documentation and published by . This book was released on 1963 with total page 698 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Company Taxation in Western Europe by : International Bureau of Fiscal Documentation
Download or read book Company Taxation in Western Europe written by International Bureau of Fiscal Documentation and published by . This book was released on 1969 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt: Overview of the corporate income tax structures of the EEC countries.
Book Synopsis Corporate Taxation in Europe by : Deloitte, Haskins & Sells
Download or read book Corporate Taxation in Europe written by Deloitte, Haskins & Sells and published by . This book was released on 1980 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Company Taxation in Western Europe by : Mees (R.) & Zoonen, Rotterdam
Download or read book Company Taxation in Western Europe written by Mees (R.) & Zoonen, Rotterdam and published by . This book was released on 1959 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Corporate Tax Policy and Incorporation in the EU by : Ruud A. de Mooij
Download or read book Corporate Tax Policy and Incorporation in the EU written by Ruud A. de Mooij and published by . This book was released on 2008 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Taxation of Private Investment Income by : J. van Hoorn
Download or read book The Taxation of Private Investment Income written by J. van Hoorn and published by . This book was released on 1967 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Towards Neutral Distribution Taxes and Vanishing Tax Effects in the European Union by : Christoph Maier
Download or read book Towards Neutral Distribution Taxes and Vanishing Tax Effects in the European Union written by Christoph Maier and published by . This book was released on 2017 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Union (EU) has no explicit common income tax law. Nevertheless, Court of Justice decisions have driven EU member states to adopt more similar corporate tax systems, and thus, to align the tax treatment of corporate profit distributions--dividends and capital gains.This paper empirically analyzes the influence of the tax preferences of individual and corporate shareholders for the two corporate distribution types--dividends or capital gains--from 1990 to 2012. In the first years of the observation period, European tax systems have provided opposing tax advantages, where individual shareholders have preferred capital gains and corporate shareholders have preferred dividends. To account for these differences depending on the firm's shareholder structure, we derive firm-specific tax preferences for profit distributions. Our empirical analysis reveals that--in line with current literature--the firm-specific tax preferences indeed affect dividend payments. Moreover, we show that in contrast to our detailed study, a simplified approach to measure tax effects on distributions overestimates this influence. In subsequent years, as European Court of Justice decisions have indirectly aligned EU corporate tax systems, we find that tax preferences have converged to a great extent with the tendency to equal tax treatment of dividends and capital gains for both--individual and corporate--shareholder groups. In line with this development, we find that the association of tax preferences and distribution policies vanishes in the last years of the observation period. Our study implies that the EU common regulatory framework, even in the absence of explicit law, can affect corporate distribution decisions and foster neutral taxation of dividends and capital gains across EU member states.
Book Synopsis Tax Harmonization in the European Common Market by : J. H. Christiaanse
Download or read book Tax Harmonization in the European Common Market written by J. H. Christiaanse and published by . This book was released on 1971 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities by : Marjaana Helminen
Download or read book The Dividend Concept in International Tax Law:Dividend Payments Between Corporate Entities written by Marjaana Helminen and published by Springer. This book was released on 1999-12-09 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis EU Freedoms, Non-EU Countries and Company Taxation by : D.S. Smit
Download or read book EU Freedoms, Non-EU Countries and Company Taxation written by D.S. Smit and published by Kluwer Law International B.V.. This book was released on 2012-06-01 with total page 822 pages. Available in PDF, EPUB and Kindle. Book excerpt: In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
Book Synopsis International Aspects of Dividend Relief by : Charles E. Jr McLure
Download or read book International Aspects of Dividend Relief written by Charles E. Jr McLure and published by . This book was released on 1979 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines international aspects of the provision of relief from the double taxation of dividends that now occurs under the "classical" American system of taxing corporate income to both corporations and shareholders. It reviews recent American debate over integration and dividend relief, the systems of dividend relief now being used in Europe, and commonly accepted standards for judging international tax policy. These standards are employed in the appraisal of existing arrangements in Europe, possible alternative systems for international taxation in a world of dividend relief, and, using the European-American situation as an example, relations between countries with dividend relief and those with classical systems
