When companies finance their investment via the international markets for stocks and bonds, relief from domestic personal taxes on dividends and capital gains will not reduce the cost of capital. Some authors have shown that even for small domestic companies whose shares are not traded...

Virgin Holding SA v. Commissioner of Taxation was a decision in the Federal Court of Australia in late 2008. It concerned a very important issue in the interpretation of the Australia-Swiss double taxation conventions. This was whether the term "income tax" included tax on capital gains. The...

Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...

In the first half of the 20th century, Italian scholars of public finance debated J. S. Mill's theorem on the double taxation of savings. Building on I. Fisher's contribution, L. Einaudi started the discussion, which lasted for some 30 years, involving a significant number of scholars. This...