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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.
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Loot
Nadine Gordimer
Paperback
(2)
R383
R310
Discovery Miles 3 100
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