TAXATION OF BRANCHES AND SUBSIDIARIES IN WESTERNEUROPE CANADA AND THE USAPDF电子书下载

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1. Domestic legislation and tax treaties 31

1. Branch and subsidiary 31

2. The effect of tax treaties upon the tax-payer’s liability 32

3. The OECD model convention and modern tax treaties 35

4. The imputation system and tax treaties 36

5. Corporate residence and the personal scope of tax treaties 41

6. Corporate residence and domestic legislation 41

7. Taxes on income: source and residence 43

8. Taxation of foreign income of resident companies 44

9. The effect of the imputation system on the taxation of foreign income 46

10. Corporate residence and taxes on income and on net worth 49

11. The treaty rules on dual residence 50

12. Taxes covered by double taxation agreements 51

13. Tax treaties and the taxation of business and investment income by the country of source 53

14. The avoidance of international double taxation by the country of residence 56

15. Multinational groups and allocation of profits 59

2. Income taxation of branches and subsidiaries of non-resident companies 65

16. The basic principles of the OECD model 65

17. Permanent establishment vs…separate legal entity 67

18. Dealing at arm’s length 72

19. Non-discrimination and disparity in treatment 82

3. Choice and patterns 87

20. Commercial, legal, and tax considerations 87

21. Base companies 91

22. Tax cost of alternatives to share capital 104

4. Company law and tax law 107

23. Company and partnership 107

24. Foreign companies 118

25. Migration 133

26. Residence 134

5. Form and substance 137

27. Civil law and English common law 137

28. Trust and Treuhand 139

29. Civil law countries 142

30. Common law countries 149

6. Double taxation: mitigation and avoidance 155

31. Double taxation 155

32. Corporate profit distributions 156

33. Affiliation privilege 156

34. Holding companies 160

35. Consolidation 162

36. Foreign branch business income 165

7. The nine member states of the European Communities and the United States 169

37. Taxation of companies and individual shareholders in the European Communities 169

38. Belgium 171

39. Denmark 179

40. France 180

41. Germany 187

42. Ireland 205

43. Italy 206

44. Luxemburg 207

45. The Netherlands 210

46. United Kingdom 211

47. United States 213

8. Western Europe, Canada, and the USA 221

48. Summary of significant taxes levied on business income 222

49. Summary of significant taxes levied on net worth 230

50. Withholding taxes on dividends paid by a resident company to a non-resident corporate shareholder 234

51. Withholding taxes on interest paid by a resident company to a non-resident company 240

52. Withholding taxes on royalties paid by a resident company to a non-resident company 246

Table of Legislation 251

Table of Treaties 259

Table of Cases 265

Bibliography 269

Index 274

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