Effects of the Tax Regulations on the Taxation of Income from Foreign Corporations

The present article integrates the effects of the tax regulations on the taxation of income from foreign corporations in the discounted cash flow method. The item to be assessed is foreign corporation that is allocated funds (equity capital or borrowed capital) by a domestic shareholder or an unaffiliated third party. In this cross-border case, the decision in favor of one financing alternative or the other will at the same time determine the extent to which the capital yields associated with the financing are liable to taxation in Germany or abroad. The amount of the tax shield therefore not only depends on the deductibility of interest payments on debt, it also depends on the rate of tax abroad. When assessing the company it will therefore be necessary to bear in mind both domestic and overseas tax regulations, domestic and overseas tax rates as well as any existing double taxation agreements