Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective write by Erwin Nijkeuter. This book was released on 2012-08-01. Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective available in PDF, EPUB and Kindle. 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.
Taxation of Intercompany Dividends Under Tax Treaties and EU Law
Taxation of Intercompany Dividends Under Tax Treaties and EU Law - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Taxation of Intercompany Dividends Under Tax Treaties and EU Law write by Guglielmo Maisto. This book was released on 2012. Taxation of Intercompany Dividends Under Tax Treaties and EU Law available in PDF, EPUB and Kindle. 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.
Taxation of EU Cross-Border Corporate Dividends
Taxation of EU Cross-Border Corporate Dividends - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Taxation of EU Cross-Border Corporate Dividends write by Carlo Garbarino. This book was released on 2013. Taxation of EU Cross-Border Corporate Dividends available in PDF, EPUB and Kindle. This paper addresses the tax treatment of EU inbound dividends in the EU Member States where the corporate (rather that individual) shareholders are resident, that is dividends paid by a company that is resident in a EU Member State to a corporate recipient shareholder that is resident in a EU Member State, including those dividends not covered by the Parent-Subsidiary Directive ("corporate dividends"). The paper adopts a comparative approach aimed at providing an explanation of the convergence of policies relating corporate dividends of the EU countries of residence of recipient corporate shareholders in the EU in the last decade, a convergence not fully explained by the top-down harmonization introduced by the Parent-Sub Directive. The paper describes the process of convergence towards exemption for corporate dividends (section 2), and then provides an evolutionary explanation of that process by adopting an evolutionary approach (section 3), together with a discussion of the circulation of the participation exemption model through tax transplants in combination with the ECJ case law (section 4). The paper concludes with comments on the intra-model competition among sub-models of participation exemption (section 5).
The Integration of Corporate and Personal Taxes in Europe
The Integration of Corporate and Personal Taxes in Europe - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook The Integration of Corporate and Personal Taxes in Europe write by Michael P. Devereux. This book was released on 1997. The Integration of Corporate and Personal Taxes in Europe available in PDF, EPUB and Kindle. 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.
Non-Discrimination and the Taxation of Cross-Border Dividends
Non-Discrimination and the Taxation of Cross-Border Dividends - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Non-Discrimination and the Taxation of Cross-Border Dividends write by Malcolm Gammie. This book was released on 2023. Non-Discrimination and the Taxation of Cross-Border Dividends available in PDF, EPUB and Kindle. At a domestic level, dividend tax systems are usually designed to relieve the economic double taxation of corporate profits and are related to the personal taxation of savings income. Increasingly over the last 40 years, however, international considerations have intruded upon domestic tax policy. Source country taxation of corporate profits and residence country personal taxation of dividends have limited domestic tax policy options and decoupled corporate and personal tax systems. This article examines the issues for dividend tax policy in an international setting and the role of bilateral tax treaties in addressing those issues. The article explains how, within the European Union, the freedoms guaranteed by the EU Treaties have dictated Member States' tax policy options. It concludes that general non-discrimination principles, in contrast to specific treaty provisions, have a limited role to play in resolving the competing claims of source and residence countries to tax the return on corporate activity.Full-text Paper.
