Prevention of double non-taxation: an analysis of cross-border financing from a german perspective

• Autores: Christian Kahlenberg
• Localización: Intertax, ISSN 0165-2826, Vol. 43, Nº. 3, 2015, págs. 218-244
• Idioma: inglés
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• Dialnet Métricas: 1 Cita
• Resumen

  • The present article deals with the problem of double non-taxation arising from intragroup cross-border financing activities. In this context, the author explains selected financing strategies from a German outbound investment to identify distinctions or loopholes between the involved countries. Afterwards, specific and conceivable counter measures will be discussed in particular, such as the Organization for Economic Co-operation and Development (OECD) and the EU Commission have been addressed. Finally, the author comes to the conclusion that a correspondence principle could be purposeful to counter double non-taxation but only, if such a provision will introduce as a domestic and as a treaty rule as well.