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The International Tax Law Concept of Dividend 2nd ed


ISBN13: 9789041183941
Previous Edition ISBN: 9789041132062
Published: June 2017
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £154.00



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The International Tax Law Concept of Dividend is a unique work that discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved.

The distribution of profits between corporations’ residents in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. 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.

What’s in this book:-

This study covers different types of inter-corporate cross-border arrangements where an investor may receive a ‘dividend equivalent return’ directly from a corporate entity or indirectly through a third party. The author examines the tax classification of various inter-corporate transactions, including the following:-

  • payments made under dividend-stripping arrangements;
  • fictitious profit distributions;
  • economic benefits in the context of transfer pricing;
  • returns on debt-equity hybrids; and
  • interest payments in thin capitalization situations and distributions following liquidation.
How this will help you:-

The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the base erosion and profit shifting (BEPS) development. The approaches adopted in different states’ national tax law are covered by a more general analysis.

The comprehensive coverage and the practical nature of this book make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

Subjects:
Taxation
Contents:
Preface
List of Abbreviations
CHAPTER 1 Introduction
CHAPTER 2 Tax Treatment of Inter-Corporate Cross-Border Dividends
CHAPTER 3 Interaction among Different Legal Systems of International Tax Law
CHAPTER 4 Different Dividend Concepts in International Tax Law
CHAPTER 5 Dividend-Distributing Entities
CHAPTER 6 Dividend-Stripping and the Dividend-Generating Relationship
CHAPTER 7 Fictive Distributions as a Dividend
CHAPTER 8 Classification of Economic Benefits from Corporations to Their
CHAPTER 9 Classification of Return on Debt-Equity Hybrids
CHAPTER 10 Classification of Interest in Thin Capitalization Situations
CHAPTER 11 Classification of Liquidation Distributions
CHAPTER 12 Concluding Remarks
Bibliography
Index

Series: International Taxation

The International Tax Law Concept of Dividend 2nd ed (eBook) ISBN 9789041183958
Published June 2017
Kluwer Law International
£154.00
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Tax Sovereignty in the BEPS Era ISBN 9789041167071
Published June 2017
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Taxation and Migration (eBook) ISBN 9789041161444
Published October 2015
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£159.00
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Taxation and Migration ISBN 9789041161369
Published October 2015
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Taxation of Derivatives ISBN 9789041159779
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The VAT/GST Treatment of Public Bodies ISBN 9789041146632
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Science, Technology and Taxation ISBN 9789041131256
Published July 2012
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Immovable Property under VAT: A Comparative Global Analysis ISBN 9789041131263
Published May 2011
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Transfer Pricing and the Arm's Length Principle in International Tax Law ISBN 9789041132703
Published September 2010
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Systems of General Sales Taxation: Theory, Policy and Practice ISBN 9789041128324
Published August 2009
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£185.00
Taxpayers Rights: Theory, Origin and Implementation ISBN 9789041126504
Published September 2007
Kluwer Law International
£250.00
Tax Treaty Law and EC Law ISBN 9789041126290
Published August 2007
Kluwer Law International
£182.00
Tax Investment Incentives in Foreign Direct Investment ISBN 9789041122285
Published April 2004
Kluwer Law International
£196.00
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International and Comparative Taxation: Essays in Honour of Klaus Vogel ISBN 9789041198419
Published September 2002
Kluwer Law International
£154.00
£243.00