Foreign Investment Fund Regimes: An Overview of Policies, Structures, and Issues
Victoria University of Wellington; Institut für Österreichisches und Internationales Steuerrecht, Wirtschaftsuniversität Wien; Monash University
TAXING OFFSHORE INVESTMENT INCOME: A COMPARATIVE REVIEW OF STRUCTURAL, pp. 1-19, John Prebble, ed., Fiscal Publications, 2006
The expression “foreign” or “overseas investment fund regime” can be misleading. The direct targets of such a regime are local residents of the country that enacts the regime. Overseas investment fund regimes aim only indirectly at investment funds in other countries. The objective of a foreign investment fund regime is to tax local residents in their share of income derived by funds in which the have invested. They try to prevent income escaping tax altogether through diversion to foreign jurisdictions. Secondly, they try to frustrate deferral by taxing income to the economic beneficiary as it accrues, though the income may not be distributed to the taxpayer for some years.
Number of Pages in PDF File: 19
Keywords: Foreign investment fund regimes, anti-avoidance, capital export neutrality, Jurisdiction
JEL Classification: K33, K34Accepted Paper Series
Date posted: May 14, 2010 ; Last revised: July 6, 2011
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