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In any accounting period, a company may pay a form of corporate income tax on its taxable profit which reduces the amount of post-tax profit available for distribution by dividend to shareholders. In the absence of a participation exemption, or other form of tax relief, shareholders may pay tax on the amount of dividend income received.
There is also a dividend exemption system that allows shareholders to exempt dividends from tax if they meet certain conditions. Germany: Dividends in Germany are taxed at a rate of 25% for non-residents, and 26.375% for residents. There is also a dividend tax credit that can be used to reduce the amount of tax that is owed on dividends.
The taxation at the level of a shareholder (shareholders or partners) depends on whether the shareholder is an individual or a corporation: If the shareholder is an individual , the distribution as dividend falls under the Abgeltungsteuer with a flat rate of 25 % plus a 5.5 % solidarity surcharge.
For other dividends to qualify, the Dutch shareholder or affiliates must own at least 5% and the subsidiary must be subject to a certain level of income tax locally. [176] Some countries, such as Singapore, [177] allow deferment of tax on foreign income of resident corporations until it is remitted to the country.
It amended the Tax Equity and Fiscal Responsibility Act of 1982 to repeal, as of June 30, 1983, provisions which require the withholding of tax on interest and dividends. It provided a system of backup withholding for taxpayers who underreport interest and dividend income or who fail to provide accurate taxpayer information.
Most income tax systems levy tax on the corporation and, upon distribution of earnings (dividends), on the shareholder. This results in a dual level of tax. Most systems require that income tax be withheld on distribution of dividends to foreign shareholders, and some also require withholding of tax on distributions to domestic shareholders.
A special thin capitalization rule penalizes subsidiaries of foreign shareholders if, instead of remitting after-tax dividends, they elect to pay interest on loans from shareholders. The Code effectively forces these companies to reclassify excessive interest into non-deductible dividends. [65]
Dividends received by resident individuals and corporations are included in taxable income by most countries. A foreign tax credit is then allowed for any foreign income taxes paid by the shareholder on the dividends, such as by withholding of tax. Where the country taxes dividends at a lower rate, the tax eligible for credit is generally reduced.