Volume 39 (2011) / Issue 11

Paulus Merks, 'Dividend Withholding Tax Planning Techniques: Part 2' (2011) 39 Intertax, Issue 11, pp. 526–533


Although there is a confounding variety of cross-border dividend withholding tax planning techniques available to the modern corporate taxpayer, this study has sought to identify, analyse and categorize these techniques in abstracto and, unless stated otherwise, without linking these techniques to particular countries.

Whereas Part 1 of this two-part study focused on the so-called formal dividend withholding tax planning techniques, the underlying Part 2 identifies, analyses and categorizes the so-called substantive dividend withholding tax planning techniques. In addition, this Part 2 provides a framework whereby the various dividend withholding tax planning techniques can be categorized in a consistent and universal manner.

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ISSN: 0165-2826
ID: TAXI2011054