Download International Company Taxation: An Introduction to the Legal by Ulrich Schreiber, Peter Müller PDF

By Ulrich Schreiber, Peter Müller

The publication is written for college students of commercial economics and tax legislation. It makes a speciality of funding and financing judgements in cross-border situations.

In specific, the publication offers with: felony buildings of foreign corporation taxation, overseas double taxation, Source-based and residence-based source of revenue taxation, foreign funding and revenue moving, overseas company tax making plans, foreign tax making plans and ecu legislations, Harmonization of company taxation within the eu Union, foreign tax making plans and tax accounting.

International tax legislation is designed to prevent overseas double taxation and to wrestle foreign tax avoidance. however, businesses making an investment in overseas nations might be afflicted by foreign double taxation of earnings. however, those businesses can also be in a position to make the most a global tax fee differential by way of cross-border tax making plans.

Ulrich Schreiber holds the chair of commercial management and enterprise Taxation on the college of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach company overview (sbr) and is affiliated with the Centre for ecu fiscal examine (ZEW) as a examine affiliate. Ulrich Schreiber is a member of the tutorial Advisory Board of the Federal Ministry of Finance.

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Sample text

Interest payments received are subject to tax in the low-tax country. Again, profit is shifted from the high-tax country to the low-tax country and the multinational can take advantage of the international tax rate differential. European Tax Planning Europe is an especially challenging area for international tax planning because there are remarkable differences in corporation tax rates across European countries. 10 Internationally diverging corporation tax rates give rise to international tax planning by means of tax rate arbitrage.

Taxes may also affect market prices, thus impacting on gross cash flows. The investors could, for example, shift the income tax burden to employees through lower wages or to customers through higher prices. In the following, it is assumed that the profit tax burden cannot be shifted away to other parties. All other things being equal, a reduction of the investment’s net cash flows reduces the NPV. Secondly, taxes affect the yield of the capital market investment. If the financial investment is taxed, the interest rate has to be cut by the tax rate applied to financial investments.

Taking sales into account, allocates a company’s profit to countries where goods are delivered or services performed. Although it seems to be plausible from an economic point of view to allocate a company’s total profit according to factors that are related to production and sales, it is essentially unclear what amount of profit is “caused” by invested capital and employed workforce or generated revenues. We lack any economic theory how to allocate a firm’s profit fairly according to the input factors involved.

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