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Table of Contents
Introduction
Tax treatment of the inter-corporate cross-border dividends
Interaction among different legal systems of international tax law
Different dividend concepts ininternational tax law
Dividend- distributing entities
Dividend-stripping and the dividend- generating relationship
Fictive distributions as a dividend
Classification of economic benefits from corporations to their shareholders in the form of transfer prices
Classification of return on debt-equity hybrids
Classification of interest in thin capitalization situations
Classification of liquidation distributions
Concluding remarks.
Tax treatment of the inter-corporate cross-border dividends
Interaction among different legal systems of international tax law
Different dividend concepts ininternational tax law
Dividend- distributing entities
Dividend-stripping and the dividend- generating relationship
Fictive distributions as a dividend
Classification of economic benefits from corporations to their shareholders in the form of transfer prices
Classification of return on debt-equity hybrids
Classification of interest in thin capitalization situations
Classification of liquidation distributions
Concluding remarks.