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
- Mark Bowler-Smith
- Thao Le
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