Abstract
This paper deals with the problematic nature of imputation systems of corporate and shareholder taxation in the presence of cross-boarder dividends. It analyses ways and means of getting imputation systems in accordance with the European freedom of establishment and the free movement of capital. These two freedoms encompass requirements on the construction of an imputation system as well as the determination of an indirect credit which are shown in the article. It is pointed out, that meeting these demands results in further problems which can only be eased in some cases but not be solved. Finally a proposal for a cross-boarder imputation system is given.
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