Comparison of US, UK and German corporate income tax systems with respect to dividend relief

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GRIN Verlag, Aug 12, 2004 - Business & Economics - 23 pages
Essay from the year 2004 in the subject Business economics - Accounting and Taxes, grade: Distinction (83%), The University of Sydney (Faculty of Law), course: Comparative Corporate Taxation, language: English, abstract: This essay briefly describes the main different theoretical approaches (tax systems) designed to alleviate the double burden of corporation tax and shareholder income tax under Part 2. Parts 3- 5 explain how the problem of dividend double taxation was tried to be solved in the heterogeneous tax systems of the Germany, the UK and the US. However, the essay will not cover the different double tax avoiding treaties in force in those countries.
 

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Contents

INTRODUCTION
GENERAL DESCRIPTION OF DIFFERENT TAX SYSTEMS
1
C DOUBLE TAXATION AVOIDING SYSTEMS
3
THE GERMAN APPROACH
4
B THE NEW GERMAN SHAREHOLDER RELIEF SYSTEM
5
C DISTORTIONS OF THE GERMAN CORPORATE TAX SYSTEM
6
THE UK APPROACH
9
B CHANGES MADE TO THE ACT SYSTEM
10
C DISTORTIONS UNDER THE UK CORPORATE TAX SYSTEM
11
THE US APPROACH
13
B DISTORTIONS UNDER THE US CLASSICAL SYSTEM
15
CONCLUSION
18
REFERENCES
19

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