By Ulrich Schreiber, Peter Müller
The publication is written for college students of commercial economics and tax legislations. It makes a speciality of funding and financing judgements in cross-border situations.
In specific, the ebook offers with: criminal buildings of overseas corporation taxation, foreign double taxation, Source-based and residence-based source of revenue taxation, overseas funding and revenue moving, overseas company tax making plans, foreign tax making plans and eu legislations, Harmonization of company taxation within the eu Union, overseas tax making plans and tax accounting.
International tax legislations is designed to prevent overseas double taxation and to strive against overseas tax avoidance. however, businesses making an investment in international international locations may perhaps be afflicted by overseas double taxation of gains. nevertheless, those businesses can also be capable of make the most a world tax price differential through cross-border tax making plans.
Ulrich Schreiber holds the chair of industrial management and enterprise Taxation on the collage of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach company assessment (sbr) and is affiliated with the Centre for ecu financial learn (ZEW) as a study affiliate. Ulrich Schreiber is a member of the educational Advisory Board of the Federal Ministry of Finance.
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Extra info for International Company Taxation: An Introduction to the Legal and Economic Principles
5%. 73. The real investment becomes unprofitable after taxes. 30 2. Fundamentals of International Tax Planning With respect to the tax effects on real investments, two effects can be discerned: the tax rate effect and the tax base effect. The tax rate effect depends on the relationship of the tax rates applying to real investment and to financial investment. Comparatively low real profit tax rates favor real investment (ĲRI < ĲFI ). The tax base effect depends on the depreciation rules. Front-loaded depreciation advantages real investment because it reduces the tax base at the beginning of the investment period and defers the tax payments to the future.
The transfer of assets and the exchange of shares. The MD stipulates that Member States shall refrain from taxing gains upon a cross-border restructuring subject to certain conditions. Companies involved in cross-border restructuring must be incorporated, resident in a Member State for tax purposes and subject to corporation tax. Tax exemption is only grant- 24 1. International Company Taxation ed if the transferred assets can be attributed to a permanent establishment of the Member State of the transferring company.
4 International Profit Allocation 21 Because the foreign permanent establishment and the domestic parent company (the head office) are an economic unit as well as a legal unit (in the sense that the permanent establishment is not legally separate), it is impossible for the principal company to enter into legal contracts with the foreign permanent establishment. Thus, as opposed to legally separated subsidiaries, transfer prices stipulated in legal contracts governing the internal transactions are non-existent.
International Company Taxation: An Introduction to the Legal and Economic Principles by Ulrich Schreiber, Peter Müller