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WU Research
Research . 2020
Data sources: WU Research
SSRN Electronic Journal
Article . 2020 . Peer-reviewed
Data sources: Crossref
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Withholding Tax Rates on Dividends: Symmetries vs. Asymmetries in Double Tax Treaties

Authors: Petkova, Kunka;

Withholding Tax Rates on Dividends: Symmetries vs. Asymmetries in Double Tax Treaties

Abstract

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 some countries in their DTTs prefer homogenous withholding tax rates over separate rates for participation and portfolio dividends. In a theoretical model, I demonstrate why home countries may have an interest in a high withholding tax rate in the host country, even though they do not receive the revenue from this tax. Further, I find confirming evidence that a reason for having asymmetric withholding tax rates on dividends is an existing spatial dependence on the rates of the countries’ peers that may be a driving factor for setting asymmetric rates. Finally, I confirm that the spread itself (i.e., the difference between the portfolio and participation dividends negotiated in the tax treaty) is also affected by the peer countries.

Country
Austria
Keywords

Double Tax Treaties, Withholding Tax Rates, Dividends, Portfolio Dividends, Participation Dividends, WU International Taxation Research Paper Series, jel: jel:F23, F53, H25, H26, H73, H87, K34

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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
0
Average
Average
Average
Green