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Taxation of Intercompany Dividends under Tax Treaties and EU Law comprising the proceedings and working documents of an annual seminar held in Milan on 1 October 2011, 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.
This book is essential reading for all those dealing with cross-border taxation, EU tax law and tax treaty issues.