The Resource Shareholder debt financing and double taxation in the OECD : an empirical survey with recommendations for the further development of the OECD Model and international tax planning

Shareholder debt financing and double taxation in the OECD : an empirical survey with recommendations for the further development of the OECD Model and international tax planning

Label
Shareholder debt financing and double taxation in the OECD : an empirical survey with recommendations for the further development of the OECD Model and international tax planning
Title
Shareholder debt financing and double taxation in the OECD : an empirical survey with recommendations for the further development of the OECD Model and international tax planning
Creator
Subject
Language
eng
Summary
This article analyses for the first time the problem complex of double taxation due to not coordinated shareholder debt-financing rules in all thirty OECD Member States by means of cross-border tax assessment simulations for all double taxation cases in the OECD. The survey shows that there exists a considerable tax differential within the OECD that gives the incentive for international tax planning using shareholder debt financing. All 870 relations between OECD Member States are examined and the enormous extent of potential double taxation due to shareholder debt-financing rules within the OECD is shown. Therefrom, recommendations for the further development of the OECD Model are deducted that are measured by the objective of fair apportionment of tax revenues, the objective of avoidance of double taxation, the objective of community law conformity, and the objective of feasibility. As realistically as possible, nobody can expect a further development of the OECD Model to solve the problem of double taxation due to not coordinated shareholder debt-financing rules in the near-future recommendations for international tax planning are deducted
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 38 (2010),
http://library.link/vocab/creatorName
Zielke, R
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • OECD Model
  • debt capital
  • effective tax rate
  • double taxation
  • international tax planning
Label
Shareholder debt financing and double taxation in the OECD : an empirical survey with recommendations for the further development of the OECD Model and international tax planning
Instantiates
Publication
Label
Shareholder debt financing and double taxation in the OECD : an empirical survey with recommendations for the further development of the OECD Model and international tax planning
Publication

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