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This work aims to explore the main distortions arising from the economic double taxation of distributed profits in three member states of the European Union: Portugal, the United Kingdom and the Netherlands. The author presents a comprehensive comparative analysis of the tax implications of this form of double taxation from a legal point of view. To this end, both domestic laws and international tax treaties are analysed, inward and outward investment is covered and dividend income tax burdens are ascertained having regard to those taxes that directly influence the effective dividend income tax rate. The results of this analysis are assessed in light of the tax principles of neutrality, efficiency, non-discrimination under EU law, and the objectives of fair distribution of revenue between member states, simplicity and prevention of tax evasion. The author concludes that well-accepted tax principles, such as the principles of worldwide taxation and vertical equity, operate less efficiently within the overall tax system. Instead, the source principle is gaining momentum, with simplicity and neutrality aims prevailing over distributional criteria. From a theoretical point of view therefore, the principle of capital import neutrality is of growing importance as compared with the principle of capital export neutrality. Furthermore, it is suggested that problems remain with regard to the balance between debt financing and equity financing, unless an exemption system is in place, further complicated by the more favourable treatment given to capital gains. Neither classical nor imputation systems provide a satisfactory answer to these problems.
Table of Contents:
Introduction. 1. What is Integration?; 2. Typology of Tax Systems; 3. In Search of an EU Tax System. Part I - Portuguese Corporation Tax System. 1. What Can be Learned from the Past?; 2. Portuguese Corporation Income Tax System; 3. Conclusions; Part II - UK Corporation Tax System. 1. Introduction; 2. UK Corporation Income Tax System; 3. The Tax Treatment of Equity and Debt; 4. An Overview of the UK Corporation Tax System: Threats and Opportunities. Part III - The Netherlands Corporation Tax System. 1. Introduction; 2. Dutch Corporation Income Tax System; 3. The Tax Treatment of Equity and Debt; 4. A View into the Future. Appendix: The Netherlands Double Tax Convention Model - Main Features. Part IV - Towards an EU Corporation Tax System. 1. Introduction; 2. Jurisdictional Claims. 3. Comparison of Tax Burdens; 4. Fiscal Implications; 5. The Problem of Equity and Debt; 6. Conclusions. References and Selected Bibliography. General and Comparative Bibliography; Legislation. Index.