From Imputation to Exemption: Designing Corporate-Shareholder Integration for Cross-Border Investment in Open Economies
Year: 2026
Type: article
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.
Source: European Taxation
DOI: 10.59403/fz6zrj
Authors: Mark Bowler-Smith, Thao Le
Language: English
Topic: Taxation and Legal Issues
Subfield: Accounting
Domain: Social Sciences
Open Access status: green
OpenAlex ID: W7159943973