International Double Taxation. Content, Consequences and Avoidance (II)

Abstract

This paper investigates the choice of international double taxation avoidance methods by two different companies engaged in cross border economic relations, in countries that mutually exchange foreign direct investment. We are examining the tolerance of Romanian and French investors to certain levels of tax generated by different scenarios: no Double Taxation Treaty concluded between the two countries; the existence of a Double Taxation Convention adopted by the two countries. The second part of the paper is divided into multiple sections concerning each unilateral method of avoiding the double taxation risk. Even in the presence of an international double taxation agreement, uncertainty is not entirely eliminated, affecting the foreign investment performance. Therefore, double taxation risk control is performed using two methods: exemption method and credit method (as prescribed by the OECD model treaty).

Keywords

• double taxation
• income
• wealth
• capital
• legal person
• exemption method
• credit method