Abstract
AbstractThis study is assigned to international tax law. It elaborates on various innovative strategies for tax-optimized profit repatriation from foreign subsidiaries. As an example, the analysis is carried out against the background of the country constellation USA/European Union. However, the results and strategies can be applied to other country constellations. The elaboration of profit repatriation strategies solves a significant taxation problem for investments in foreign subsidiaries, namely the incurrence of withholding tax in the subsidiary's foreign country of residence. At the same time, a contribution is made to expanding the literature. Tax effective profit repatriation strategies regarding investments in foreign subsidiaries have hardly been derived and discussed in the literature.
Funder
IU Internationale Hochschule GmbH
Publisher
Springer Science and Business Media LLC
Reference44 articles.
1. Aluko, Bioye Tajudeen, and Abdul-Rasheed. Amidu. 2005. Corporate business valuation for mergers and acquisitions. International Journal of Strategic Property Management 9 (3): 173–189. https://doi.org/10.1080/1648715X.2005.9637535.
2. Amberger, H.J., and S. Kohlhase. 2023. International taxation and the organizational form of foreign direct investment. Journal of International Business Studies. https://doi.org/10.1057/s41267-023-00614-1.
3. Aydin, Nurhan. 2017. Mergers and acquisitions: a review of valuation methods. International Journal of Business and Social Science 8 (5): 147–151.
4. Barsuk, K. et. al (2016). Exceptions to branch profits tax available to foreign corporations with U.S. tax compliance obligations, The Tax Adviser, https://www.thetaxadviser.com/issues/2016/mar/exceptions-to-branch-profits-tax-available-to-foreign-corporations-with-us-tax-obligations.html.
5. Benedetti, Julie, and Arnaud Van Waeyenberge. 2019. Structural consequences of cross-border company seat transfers within the EU in the latest Court of Justice case law: Polbud. European Law Review 44 (3): 416–430.