By Ulrich Schreiber, Peter Müller
The booklet 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 e-book bargains with: felony 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 ecu legislations, Harmonization of company taxation within the eu Union, foreign tax making plans and tax accounting.
International tax legislations is designed to prevent foreign double taxation and to strive against overseas tax avoidance. however, businesses making an investment in international international locations might be afflicted by overseas double taxation of earnings. nonetheless, those businesses can also be capable of make the most a global tax price differential by way of cross-border tax making plans.
Ulrich Schreiber holds the chair of industrial management and enterprise Taxation on the college of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach enterprise assessment (sbr) and is affiliated with the Centre for eu fiscal study (ZEW) as a examine affiliate. Ulrich Schreiber is a member of the educational Advisory Board of the Federal Ministry of Finance.
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Additional info for International Company Taxation: An Introduction to the Legal and Economic Principles
International Company Taxation a consequence, the permanent establishment may, for example, deduct interest payments for a loan granted by the principal company. g. intermediate goods) to the permanent establishment, the principal company accounts for the revenues, while the permanent establishment deducts the corresponding expenses. e. CUPM, CPM, RPM, TNMM, and TPSM apply accordingly. In effect, the permanent establishment is treated as a separate and independent enterprise only for purposes of profit attribution, which from a legal point of view is mere fiction.
Affiliated corporations are legally distinct entities and may enter into legal contracts which are in principal accepted by tax law. To determine the profit of a subsidiary, internal transactions are accounted for on the basis of transfer prices stipulated in legal contracts. For tax purposes, transfer prices have to conform to the arm’s length standard (Art. 9 Para. 1 OECD-MT) implying a comparison of the transfer price to the market price of a comparable transaction. Because market prices for international transactions rarely exist, multinational companies experience an incentive to make use of the imprecision of transfer pricing to reduce their overall tax burden.
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. The latter requirement ensures the exit taxation of hidden reserves in cases where a Member State immediately forfeits its tax claim on the hidden reserves. 7): German G Corporation transfers a German branch to British B Corporation.
International Company Taxation: An Introduction to the Legal and Economic Principles by Ulrich Schreiber, Peter Müller