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B Influence upon the form of business organisation
The splitrate system
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15 per cent abroad advance corporation tax amount avoir fiscal benefit capital gains chargeable company tax company's convention corporation profits tax country of residence deducted distributed profits dividends paid dividends received double taxation treaty economic double taxation effect exemption favour financing foreign branch foreign companies foreign subsidiary foreign tax foreign tax credit France French German company imputation system income arising Income from Capital individual investors Ireland Irish companies Irish income tax Irish tax levied liable to Irish mitigation OECD overseas paragraph parent company permanent establishment personal income tax profits distributed rate of corporation rate of tax rate tax recipient regards relief retained profits revenue separate corporate tax separate system share Spain split rate split-rate system standard rate surtax system of company tax and corporation tax credit tax liability Tax on Income tax paid tax purposes tax rate Tax treatment tax treaty United Kingdom company withholding tax