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Taxing Corporate Profits in the EU - A Comparative Study of the Portuguese, British and Dutch Systems (Hardcover)
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Taxing Corporate Profits in the EU - A Comparative Study of the Portuguese, British and Dutch Systems (Hardcover)
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This work aims to explore the main distortions arising from the
economic double taxation of distributed profits in three member
states of the European Union: Portugal, the United Kingdom and the
Netherlands. It presents a comparative analysis of the tax
implications of this form of double taxation from a legal point of
view. To this end, both domestic laws and international tax
treaties are analyzed, inward and outward investment is covered and
dividend income tax burdens are ascertained having regard to those
taxes that directly influence the effective dividend income tax
rate. The results of this analysis are assessed in light of the tax
principles of neutrality, efficiency, nondiscrimination under EU
law and the objectives of fair distribution of revenue between
member states, simplicity and prevention of tax evasion. The author
concludes that well-accepted tax principles, such as the principles
of worldwide taxation and vertical equity, operate less efficiently
within the overall tax system. Instead, the source principle is
gaining momentum, with simplicity and neutrality aims prevailing
over distributional criteria. From a theoretical point of view,
therefore, the principle of capital import neutrality is of growing
importance as compared with the principle of capital export
neutrality. Furthermore, it is suggested that problems remain with
regard to the balence between debt financing and equity financing,
unless an exemption system is in place, further complicated by the
more favourable treatment given to capital gains. Neither classical
nor imputation systems, the author concludes, provide a
satisfactory answer to these problems.
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