Author (Person) | Kahlenberg, Christian |
---|---|
Series Title | Intertax |
Series Details | Vol.43, No.3, March 2015, p218–244 |
Publication Date | March 2015 |
ISSN | 0165-2826 |
Content Type | Journal | Series | Blog |
Abstract: The present article deals with the problem of double non-taxation arising from intragroup cross-border financing activities. In this context, the author explains selected financing strategies from a German outbound investment to identify distinctions or loopholes between the involved countries. Afterwards, specific and conceivable counter measures will be discussed in particular, such as the Organization for Economic Co-operation and Development (OECD) and the EU Commission have been addressed. Finally, the author comes to the conclusion that a correspondence principle could be purposeful to counter double non-taxation but only, if such a provision will introduce as a domestic and as a treaty rule as well. |
|
Source Link | http://www.kluwerlawonline.com/index.php?area=Journals |
Subject Categories | Taxation |
Countries / Regions | Germany |
![](https://www.europeansources.info/wp-content/uploads/esologo2.png)