From Imputation to Exemption: Designing Corporate–Shareholder Integration for Cross-Border Investment in Open Economies

This article compares classical taxation, full imputation, shareholder relief and dividend exemption as methods of integrating corporate and shareholder taxation in respect of cross-border portfolio investment. Using doctrinal analysis and stylized rate-normalized illustrations drawn from Australia and European jurisdictions, it evaluates how each model performs against neutrality, efficiency, equity and international coordination once withholding taxes and residence-state relief are taken seriously. The article argues that, while full imputation performs well domestically, dividend exemption and well-calibrated shareholder relief travel better in open economies by reducing stranded tax, administrative complexity and discriminatory spillovers.

Authors

Publication Details

Journal
European Taxation
Published
2026-04-29
DOI
https://doi.org/10.59403/fz6zrj
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

From Imputation to Exemption: Designing Corporate–Shareholder Integration for Cross-Border Investment in Open Economies

Mark Bowler-Smith, Thao Le
European Taxation
Corporate Taxation and Avoidance
article

From Imputation to Exemption: Designing Corporate–Shareholder Integration for Cross-Border Investment in Open Economies

Mark Bowler-Smith, Thao Le
article en

Abstract

This article compares classical taxation, full imputation, shareholder relief and dividend exemption as methods of integrating corporate and shareholder taxation in respect of cross-border portfolio investment. Using doctrinal analysis and stylized rate-normalized illustrations drawn from Australia and European jurisdictions, it evaluates how each model performs against neutrality, efficiency, equity and international coordination once withholding taxes and residence-state relief are taken seriously. The article argues that, while full imputation performs well domestically, dividend exemption and well-calibrated shareholder relief travel better in open economies by reducing stranded tax, administrative complexity and discriminatory spillovers.

European TaxationVol. 66(4)
Reduced inequalities
Openalex Percentile: Top 7%
Corporate Taxation and Avoidance
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