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Dividend taxation in a free capita market Kristina Stdial, Uppala University through foreign subsidiaries or foreign branches are considered here. The article is a summary of the main results of my thesis, presented at Uppsala University in May 1996.4 It is a well-known fact that the efforts to harmonize the company tax in the EC Member States have as yet shown few results. Apart from the adoption of the 'three measure package'l in 1990, not much has happened. For example, the Member States are still free to apply whichever company tax system they like. This has led to the current situation with a multitude of different systems in use in the Union. These systems provide different methods and levels of integration of the company tax and the shareholder income tax. The various countries also employ quite separate rules concerning the treatment of cross-border investments within their company tax systems. While some countries restrict the application of any relief from the so-called economic double taxation to purely domestic situations, others extend the relief to cover dividends to foreign shareholders or dividends from foreign companies as well. Further, the Member States are, outside the scope of the Parent-Subsidiary Directive,2 in
EC Tax Review – Kluwer Law International
Published: Jan 21, 1997
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