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Multinational Companies and the treatment of withholding tax in double tax treaties

ABSTRACT
The aim of this dissertation is to clarify several taxation issues between Luxembourg and Central and Eastern European countries. This is done in order to help the client to decide how to structure cross-border investments and eventually where to locate new companies. This paper will serve to strengthen and to improve the group’s tax policy internationally. Double Tax Treaties are bilateral agreements the analysis of which is necessary as their aim is the promotion and the protection of investments in the two countries involved. The tax issues that are analysed as they emerge in the Double Tax Treaty are the following: dividends, interests, and royalties payments that flow between a parent company based in Luxembourg and its subsidiary located in Central and Eastern Europe. The methodology used in the research is the analysis of interviews and the analysis of previous literature in the area. It is likely to be found that difference in tax rates and tax treatments of determined items within a multinational group leads to relevant tax savings. Finally, the implications for the structure of the group of companies arising from the research are presented.

Mostra/Nascondi contenuto.
ABSTRACT The aim of this dissertation is to clarify several taxation issues between Luxembourg and Central and Eastern European countries. This is done in order to help the client to decide how to structure cross-border investments and eventually where to locate new companies. This paper will serve to strengthen and to improve the group’s tax policy internationally. Double Tax Treaties are bilateral agreements the analysis of which is necessary as their aim is the promotion and the protection of investments in the two countries involved. The tax issues that are analysed as they emerge in the Double Tax Treaty are the following: dividends, interests, and royalties payments that flow between a parent company based in Luxembourg and its subsidiary located in Central and Eastern Europe. The methodology used in the research is the analysis of interviews and the analysis of previous literature in the area. It is likely to be found that difference in tax rates and tax treatments of determined items within a multinational group leads to relevant tax savings. Finally, the implications for the structure of the group of companies arising from the research are presented.

Tesi di Laurea

Autore: Marco Mancini Contatta »

Composta da 80 pagine.

 

Questa tesi ha raggiunto 1076 click dal 20/03/2004.

 

Consultata integralmente 2 volte.

Disponibile in PDF, la consultazione è esclusivamente in formato digitale.