Comparison of US, UK and German corporate income tax systems with respect to dividend relief
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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B CHANGES MADE TO THE ACT SYSTEM
C DISTORTIONS UNDER THE UK CORPORATE TAX SYSTEM
THE US APPROACH
B DISTORTIONS UNDER THE US CLASSICAL SYSTEM
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25 per cent 27 INTERTAX ACT System capital gains Cato Institute Classical System companies company’s CORPORATE FINANCE corporate level corporate shareholders corporate tax rate CORPORATE TAX SYSTEM distortions distributed profits Dividend Deduction System Dividend Exemption System dividend tax dividends received DOUBLE TAXATION REDUCING effective tax burden effective tax rate equity financing European Union FINANCE DECISIONS Fiscal Neutrality foreign corporations foreign dividends foreign income foreign shareholders form of business franking credit Full Tax Imputation Furthermore German National Library German system German Tax income tax rate income taxation individual income tax individual shareholders INTERNATIONAL NEUTRALITY investment investors KStG LEGAL FORM n3 supra NEUTRALITY TOWARDS CORPORATE NEUTRALITY TOWARDS LEGAL non-resident shareholders PARTIAL IMPUTATION SYSTEM personal income tax Progressive tax rate of 25 retained profits shareholder income tax shareholder level Shareholder Relief System tax avoidance tax base tax competition Tax Imputation System tax on dividends tax treaties taxation of dividends Thereby unincorporated businesses withholding tax