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Vol 22 No 7 July/August 2017

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A new edition was published, see:
The International Tax Law Concept of Dividend isbn 9789041132062

The Dividend Concept in International Tax Law

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ISBN13: 9789041197658
ISBN: 9041197656
New Edition ISBN: 9789041132062
Published: January 2000
Publisher: Kluwer Law International
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 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.

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Acknowledgements. Abbreviations. Table of Cases.
1. Introduction.
2. The Taxation of Inter-Corporate Cross-Border Dividend.
3. The Interaction between Different Legal Systems of International Tax Law.
4. Different Dividend Concepts in International Tax Law.
5. Dividend-Distributing Entities.
6. Dividend-Stripping and the Dividend-Generating Relationship.
7. Fictive Distributions as Dividend.
8. Dividend-Classification of Economic Benefits from Corporations to their Shareholders in the Form of Transfer Prices.
9. The Classification of Return on Debt-Equity Hybrids.
10. The Classification of Interest in Thin Capitalization Situations.
11. The Classification of Liquidation Distributions.
12. Concluding Remarks. Bibliography. Index.

Series: International Taxation

The International Tax Law Concept of Dividend 2nd ed ISBN 9789041183941
Published June 2017
Kluwer Law International
Tax Sovereignty in the BEPS Era ISBN 9789041167071
Published June 2017
Kluwer Law International
Taxation and Migration ISBN 9789041161369
Published October 2015
Kluwer Law International
Taxation of Derivatives ISBN 9789041159779
Published August 2015
Kluwer Law International
The VAT/GST Treatment of Public Bodies ISBN 9789041146632
Published January 2013
Kluwer Law International
Science, Technology and Taxation ISBN 9789041131256
Published July 2012
Kluwer Law International
Immovable Property under VAT: A Comparative Global Analysis ISBN 9789041131263
Published May 2011
Kluwer Law International
Transfer Pricing and the Arm's Length Principle in International Tax Law ISBN 9789041132703
Published September 2010
Kluwer Law International
Systems of General Sales Taxation: Theory, Policy and Practice ISBN 9789041128324
Published August 2009
Kluwer Law International
Taxpayers Rights: Theory, Origin and Implementation ISBN 9789041126504
Published September 2007
Kluwer Law International
Tax Treaty Law and EC Law ISBN 9789041126290
Published August 2007
Kluwer Law International
Tax Investment Incentives in Foreign Direct Investment ISBN 9789041122285
Published April 2004
Kluwer Law International
Customs Valuation and Transfer Pricing ISBN 9789041198884
Published December 2002
Kluwer Law International
International and Comparative Taxation: Essays in Honour of Klaus Vogel ISBN 9789041198419
Published September 2002
Kluwer Law International