Tag Archives | International Taxation

Tax Planning for Cross-Border Transactions

In this article we will discuss about:- 1. Conversion of a Foreign Branch to a Foreign Subsidiary 2. Repatriation of Profits 3. Liquidation of Companies 4. Cross-border Leasing 5. Foreign Direct Investment. Contents: Conversion of a Foreign Branch to a Foreign Subsidiary Repatriation of Profits Liquidation of Companies Cross-border Leasing Foreign Direct Investment 1. Conversion […]

Role of International Tax Planner

International tax planning revolves around the different tax systems in the world. The scope of taxation and tax rules differ widely. These differences create both opportunities and threats for international tax planning, and planners. For example: i. They often have differing tax rates on different sources of income (“taxable object”) and different tax treatment for […]

Participation Exemption for Taxation in Various Countries

Many jurisdictions define the term “participation exemption” widely to include any method used to avoid economic double taxation on inter-corporate dividends from shareholdings or participations. Therefore, it includes both the relief on dividend income under the special rules of “participation exemption” (also called “affiliation privilege”), and “dividend- received deduction.” Under the domestic participation exemption rules, […]

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