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Why do countries combine the exemption system for the taxation of foreign profits with domestic double taxation relief?

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  • Fuest, Clemens
  • Huber, Bernd

Abstract

Many European countries exempt foreign profits from domestic corporate taxation. At the shareholder level, however, all corporate profits are taxed, and double taxation relief is granted only for domestic corporate taxes. This paper attempts to rationalize this tax policy. In the presence of double taxation agreements which exempt foreign profits from domestic corporate taxation, countries may use shareholder taxes to tax these profits. The disadvantage of shareholder taxes is that they create incentives to sell domestic firms to foreigners. But double taxation relief for domestic profits may preserve domestic ownership. Our results imply that national dividend tax policies may be a factor contributing to the empirically observed home bias in investment.
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  • Fuest, Clemens & Huber, Bernd, 2004. "Why do countries combine the exemption system for the taxation of foreign profits with domestic double taxation relief?," Journal of International Economics, Elsevier, vol. 62(1), pages 219-231, January.
    • Handle: RePEc:eee:inecon:v:62:y:2004:i:1:p:219-231
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    1. Jack Mintz & Henry Tulkens, 2006. "Optimality Properties of Alternative Systems of Taxation of Foreign Capital Income," Springer Books, in: Parkash Chander & Jacques Drèze & C. Knox Lovell & Jack Mintz (ed.), Public goods, environmental externalities and fiscal competition, chapter 0, pages 507-532, Springer.
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    8. Clemens Fuest & Bernd Huber, 2001. "Can Corporate-personal Tax Integration Survive in Open Economies?. Lessons from the German Tax Reform," FinanzArchiv: Public Finance Analysis, Mohr Siebeck, Tübingen, vol. 57(4), pages 514-524, August.
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    Cited by:

    1. Becker, Johannes & Fuest, Clemens, 2011. "Source versus residence based taxation with international mergers and acquisitions," Journal of Public Economics, Elsevier, vol. 95(1), pages 28-40.
    2. Becker, Johannes & Fuest, Clemens, 2011. "Tax competition -- Greenfield investment versus mergers and acquisitions," Regional Science and Urban Economics, Elsevier, vol. 41(5), pages 476-486, September.
    3. Anken, F. & Beasley, J.E., 2012. "Corporate structure optimisation for multinational companies," Omega, Elsevier, vol. 40(2), pages 230-243, April.
    4. Johannes Becker & Clemens Fuest, 2011. "The taxation of foreign profits — The old view, the new view and a pragmatic view," Intereconomics: Review of European Economic Policy, Springer;ZBW - Leibniz Information Centre for Economics;Centre for European Policy Studies (CEPS), vol. 46(2), pages 92-97, March.
    5. Johannes Becker & Clemens Fuest, 2007. "Corporate Tax Policy and International Mergers and Acquisitions – Is the Tax Exemption System Superior?," CESifo Working Paper Series 1884, CESifo.
    6. George R. Zodrow, 2019. "Capital Mobility and Capital Tax Competition," World Scientific Book Chapters, in: George R Zodrow (ed.), TAXATION IN THEORY AND PRACTICE Selected Essays of George R. Zodrow, chapter 18, pages 543-570, World Scientific Publishing Co. Pte. Ltd..
    7. Johannes Becker & Clemens Fuest, 2010. "Taxing Foreign Profits With International Mergers And Acquisitions," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 51(1), pages 171-186, February.
    8. Nikolay Anguelov, 2017. "Lowering the Marginal Corporate Tax Rate: Why the Debate?," Economic Affairs, Wiley Blackwell, vol. 37(2), pages 213-228, June.

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