taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able …

affiliate is located in a low-tax country and is limited to two alternatives: repatriating taxable dividends to the parent or … against, making any direct taxable flow to the parent unnecessary. The low-tax subsidiary can also use its earnings to invest … in a related high-tax affiliate which becomes the vehicle for tax-free repatriations. Alternatively, the low-tax …