Skip to main content Accessibility help
×
Hostname: page-component-848d4c4894-wg55d Total loading time: 0 Render date: 2024-06-01T00:41:26.435Z Has data issue: false hasContentIssue false

2 - Taxation of Corporate Income When Distributed

Published online by Cambridge University Press:  29 February 2024

Peter Harris
Affiliation:
University of Cambridge
Get access

Summary

This chapter deals with taxation when a corporation distributes income. It presumes all events occur within a particular country and that the capital structure of the corporation does not change. Dividends as payments with respect to corporate rights are discussed. Corporate financing in the forms of debt and equity are explored with a consideration of hybrid instruments and thin capitalisation. The discussion proceeds to consider the fundamental features of dividends and hidden profit distributions, which have tax consequences at both the corporate and shareholder levels. The dual nature of corporate income is identified, which involves dividends constituting taxable income. With the taxation of corporate income when derived, the result is economic double taxation, the classical system. Arguments in support of and against this double taxation are considered before the discussion turns to consider the options for relieving the double taxation (dividend relief). Dividend relief options at the corporate level and the shareholder level are explored with a consideration and categorisation of recent international practice. Systems behave differently when faced with expenses in deriving dividends, preference income and dividend streaming. Finally, the manner in which a corporate tax system allocates profits as retained or distributed is considered.

Type
Chapter
Information
Corporate Tax Law
Structure, Policy and Practice
, pp. 193 - 353
Publisher: Cambridge University Press
Print publication year: 2024

Access options

Get access to the full version of this content by using one of the access options below. (Log in options will check for institutional or personal access. Content may require purchase if you do not have access.)

Save book to Kindle

To save this book to your Kindle, first ensure coreplatform@cambridge.org is added to your Approved Personal Document E-mail List under your Personal Document Settings on the Manage Your Content and Devices page of your Amazon account. Then enter the ‘name’ part of your Kindle email address below. Find out more about saving to your Kindle.

Note you can select to save to either the @free.kindle.com or @kindle.com variations. ‘@free.kindle.com’ emails are free but can only be saved to your device when it is connected to wi-fi. ‘@kindle.com’ emails can be delivered even when you are not connected to wi-fi, but note that service fees apply.

Find out more about the Kindle Personal Document Service.

Available formats
×

Save book to Dropbox

To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Dropbox.

Available formats
×

Save book to Google Drive

To save content items to your account, please confirm that you agree to abide by our usage policies. If this is the first time you use this feature, you will be asked to authorise Cambridge Core to connect with your account. Find out more about saving content to Google Drive.

Available formats
×