Price: € 120 / $ 150
Pages: 406
Published: 2005
ISBN:  90 76078 85 8
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Taxation of Cross-Border Partnerships:
Double Tax Relief in Hybrid and Reverse Hybrid Situations
Author: Dr Jesper Barenfeld - Doctoral Series: Vol. 9

Summary of contents

International juridical double taxation constitutes a significant obstacle for the development of cross-border business activities. Even though this problem has been combated for decades with ever more sophisticated methods, many difficulties are yet to be conquered.

This book deals with problems regarding international double taxation in cross-border partnership structures. The heterogeneity of these business vehicles constitutes a challenging factor for countries' legislation on foreign-entity classification. As these regimes typically disregard the tax treatment of foreign entities for domestic tax purposes, cross-border partnerships often face the risk of being treated as taxable persons in one country but as transparent in another. This is referred to as asymmetrical situations.

As shown in this book, international double taxation arising in asymmetrical situations fits badly into countries' regimes for double-tax relief. As a result, there is a considerable risk that international double taxation arising in asymmetrical situations is not appropriately relieved. In addition to identifying and analyzing the reasons for these problems, this book presents potential approaches on how to deal with them de lege ferenda.


View sample chapter    |    View table of contents

About the Author
Dr Jesper Barenfeld works as Tax Policy Advisor for the Confederation of Swedish Enterprise and deals predominantly with international tax policy issues. He also holds the positions of Affiliated Faculty Member at Jönköping International Business School, Jönköping and Senior Fellow in the Taxation Law and Policy Research Institute at Monash University, Melbourne.
About IBFD Academic Council
IBFD Doctoral Series is an initiative of IBFD Academic Council, a body established in 2000 to promote the discussion of international tax law at a high academic level and to stimulate the academic activities of IBFD. The Academic Council evaluates projects according to the sole criterion of their academic quality. Its members are appointed from among prominent academics and senior IBFD research staff members.
Every thesis published in this series has been reviewed by the Academic Council to ensure that it is of a high quality.
Other books in IBFD Academic Council's Doctoral Series:

      by Dr Zvi Daniel Altman

      by Luc De Broe
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