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Vol 23 No 3 March/April 2018

Book of the Month

Cover of Scamell and Gasztowicz on Land Covenants

Scamell and Gasztowicz on Land Covenants

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This book is now Out of Print.
A new edition has been published, the details can be seen here:
The International Tax Law Concept of Dividend 2nd ed isbn 9789041183941

The International Tax Law Concept of Dividend

ISBN13: 9789041132062
New Edition ISBN: 9789041183941
Published: August 2010
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: Out of print

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 Dividendmake it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.