内容

目次

1. Introduction 2. Tax Treatment of the Inter-corporate Cross-Border Dividends 3. Interaction among Different Legal Systems of International Tax Law 4. Different Dividend Concepts in International Tax Law 5. Dividend-Distributing Entities 6. Dividend-Stripping and the Dividend-Generating Relationship 7. Fictive Distributions as a Dividend 8. Classification of Economic Benefits from Corporations to their Shareholders in the Form of Transfer Prices 9. Classification of Return on Debt-Equity Hybrids 10. Classification of Interest in Thin Capitalization Situations 11. Classification of Liquidation Distributions 12. Concluding Remarks