The dividend concept in international tax law : dividend payments between corporate entities

Resource Information

The work The dividend concept in international tax law : dividend payments between corporate entities represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

The dividend concept in international tax law : dividend payments between corporate entities

Creator

• Helminen, M

Subject

• dividend
• dividend stripping
• interest
• cross-border dividend
• thin capitalization
• transfer pricing
• liquidation

Language

eng

Summary

This book covers the rules determining which transactions between corporations resident in different jurisdictions 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 capitalisation situations and distribution 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

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction

Series statement

Series on international taxation

Series volume

25