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 various taxable persons ("taxable subject"). [...]
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, the dividend income is exempt [...]
In this article we will discuss about imputation system of taxation in various countries. The imputation system taxes a company and then grants a partial or full dividend credit to the shareholders against the corporate tax paid by the company. The shareholders claim the imputed credits and either offset them against their own tax liability or receive a refund. This [...]