Taxation of Cross-Border Partnerships
� Double-Tax Relief in Hybrid and Reverse Hybrid Situations
   
 
Författare:Barenfeld Jesper
Titel:Taxation of Cross-Border Partnerships � Double-Tax Relief in Hybrid and Reverse Hybrid Situations
Anmärkning:Doctorial Series 9. En version av avhandlingen har tidigare utgivits av Jönköping International Business School.
Utgivningsår:2005
Omfång:405 sid.
Förlag:IBFD
ISBN:9176078858
Produkttyp:Inbunden
Typ av verk:Akademisk avhandling
Ämnesord:Skatterätt
Pris: 1421 SEK exkl. moms

 

International juridical double taxation constitutes a significant obstacle for the development of cross-border business activities. Even though this problem has been combated for decades with ever more sophisticated methods, many difficulties are yet to be conquered.

This book deals with problems regarding international double taxation in cross-border partnership structures. The heterogeneity of these business vehicles constitutes a challenging factor for countries' legislation on foreign-entity classification. As these regimes typically disregard the tax treatment of foreign entities for domestic tax purposes, cross-border partnerships often face the risk of being treated as taxable persons in one country but as transparent in another. This is referred to as asymmetrical situations.
As shown in this book, international double taxation arising in asymmetrical situations fits badly into countries' regimes for double-tax relief. As a result, there is a considerable risk that international double taxation arising in asymmetrical situations is not appropriately relieved. In addition to identifying and analyzing the reasons for these problems, this book presents potential approaches on how to deal with them de lege ferenda.

Dr Jesper Barenfeld works as Tax Policy Advisor for the Confederation of Swedish Enterprise and deals predominantly with international tax policy issues. He also holds the positions of Affiliated Faculty Member at Jönköping International Business School, Jönköping and Senior Fellow in the Taxation Law and Policy Research Institute at Monash University, Melbourne.
 
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