International Group Financing and Taxes

Beschreibung

Global tax issues under review The tax issues around international group financing have continuously been a hot topic in the academia as well as in tax practice over the last years. The decision between debt and equity financing may significantly affect both a taxpayer’s tax burden and the revenues of the countries in which the taxpayer is doing business. Traditionally, debt financing shifts the tax base from the source country to the residence country, while equity financing has the opposite effect. Multinational enterprises use intra-group debt and equity financing to realize tax arbitrage in order to reduce their overall tax burden. Naturally, many countries and tax authorities are focusing on measures that shield their tax revenues from international tax planning. The master theses contained in this volume examine these issues from a tax treaty law, Community law as well as domestic tax law perspective.
The tax issues around international group financing have continuously been a hot topic in the academia as well as in tax practice over the last years. The decision between debt and equity financing may significantly affect both a taxpayer’s tax burden and the revenues of the countries in which the taxpayer is doing business. Traditionally, debt financing shifts the tax base from the source country to the residence country, while equity financing has the opposite effect. Multinational enterprises use intra-group debt and equity financing to realize tax arbitrage in order to reduce their overall tax burden. Naturally, many countries and tax authorities are focusing on measures that shield their tax revenues from international tax planning. The master theses contained in this volume examine these issues from a tax treaty law, Community law as well as domestic tax law perspective.
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Autor*in

Christian Massoner
Director bei EY Wien im Bereich International Tax and Transactions Services, Universitätslektor und Fachautor. Zu seinen Tätigkeitsschwerpunkten zählen die steuerliche Begleitung von Unternehmenskäufen und Umstrukturierungen, internationale Steuerplanung, Konzernsteuerrecht sowie Steuerfragen der digitalen Wirtschaft und Start-ups.

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Steuern Steuerrecht Internationales Steuerrecht debt financing equity financing international

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