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The International Tax Law  Concept of Dividend, Second Edition by HELMINEN

The International Tax Law Concept of Dividend, Second Edition

By Marjaana Helminen


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Series on International Taxation Volume 36

The International Tax Law Concept of Dividend is a unique work that discusses the international tax law rules determining which transactions may be classified and taxed as dividends and how possible classification conflicts may be resolved. The distribution of profits between corporations’ residents in different jurisdictions gives rise to both significant tax planning opportunities and tax risks. 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.

What’s in this book:

This study covers different types of inter-corporate cross-border arrangements where an investor may receive a ‘dividend equivalent return’ directly from a corporate entity or indirectly through a third party. The author examines the tax classification of various inter-corporate transactions, including the following:

  • payments made under dividend-stripping arrangements;
  • fictitious profit distributions;
  • economic benefits in the context of transfer pricing;
  • returns on debt-equity hybrids; and
  • interest payments in thin capitalization situations and distributions following liquidation.

How this will help you:

The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law, including the base erosion and profit shifting (BEPS) development. The approaches adopted in different states’ national tax law are covered by a more general analysis. The comprehensive coverage and the practical nature of this book make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.

Pages 304
Last Updated 04/17/2017
Update Frequency As Needed
Product Line Kluwer Law International
ISBN 9789041183941
SKU 10059261-0001
Table of Contents


List of Abbreviations

CHAPTER 1 Introduction

CHAPTER 2 Tax Treatment of Inter-Corporate Cross-Border Dividends

CHAPTER 3 Interaction among Different Legal Systems of International Tax Law

CHAPTER 4 Different Dividend Concepts in International Tax Law

CHAPTER 5 Dividend-Distributing Entities

CHAPTER 6 Dividend-Stripping and the Dividend-Generating Relationship

CHAPTER 7 Fictive Distributions as a Dividend

CHAPTER 8 Classification of Economic Benefits from Corporations to Their

CHAPTER 9 Classification of Return on Debt-Equity Hybrids

CHAPTER 10 Classification of Interest in Thin Capitalization Situations

CHAPTER 11 Classification of Liquidation Distributions

CHAPTER 12 Concluding Remarks