By Hans Triebel
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Additional info for Higher Analysis
Providing non-profitable (loss) companies that are non-taxable (and therefore unable to use special tax deductions, allowances and tax credits) with up-front cash refunds on earned but unused tax incentives tends only to attract aggressive tax-planning to access the subsidies from government, rather than bona fide investment in the targeted sectors. Moreover, project self-sufficiency rarely materialises where investment projects are not profitable on a pre-tax basis. Where incentives cannot be expected to compensate for additional costs and business losses incurred when investing in a potential host country, then their use and the net burden imposed on the host country should be avoided.
As elsewhere in the report, “direct” (as opposed to portfolio) investment refers to a significant investment in securities. While the threshold for “significant” can vary depending on the context of the usage of the term, it typically refers to an equity interest of at least 10 per cent of the shares (measured by votes or value) of a company. 2. Dividend withholding tax (like other withholding taxes) is imposed on a gross as opposed to net basis – that is, without any deductions against the tax base [distributed profit (net of corporate tax)].
A. a. a. a. a. 0 100 100 40 0 0 40 100 100 40 40 40 0 Source country tax Residence country tax Total 40 0 40 40 0 40 0 0 0 0 40 40 0 0 0 After-tax profit 60 60 100 60 100 Residence country taxation Dividend received Grossed-up dividend Corporate income tax @ 40% (a) Creditable foreign tax (b) Foreign tax credit (min(a, b)) Net corporate income tax (CIT) Note: CIT = corporate income tax. There are two broad types of tax sparing provisions. The more common type provides home country tax sparing only in respect of foreign source income that has actually benefited from host country tax relief.