Comparison of US, UK and German corporate income tax systems with respect to dividend relief
GRIN Verlag, 2007 - 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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15 per cent abolished ACT System bias capital gains Classical System companies company’s corporate level corporate shareholders corporate tax rate CORPORATE TAX SYSTEM distortions distributed profits Dividend Deduction System Dividend Exclusion System Dividend Exemption System dividend relief dividend tax dividends received effective tax burden effective tax rate equity financing foreign corporations foreign dividends foreign shareholders form of business franking credit Full Tax Imputation Furthermore German corporate German system income tax rate individual income tax individual shareholders INTERNATIONAL NEUTRALITY investment investors KStG legal form limited liability companies maximum tax rate n3 supra non-resident shareholders Partial Imputation System Partial Integration Systems personal income tax Progressive tax proposed Dividend Exclusion rate of 25 rate on dividends residence country respect to dividend retained earnings 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