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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 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, including tax treaties, European tax law and the domestic tax law of Finland, Germany, Sweden and the United States.