Traduction de «Dividende différé » (Français → Anglais) :

R. whereas in many developing countries there exist multiple corporate income tax rates based not only on income and dividends, but also on business sectors, meaning that the sectoral allocation of resources is distorted by differences in tax rates,

S. whereas in many developing countries there exist multiple corporate income tax rates based not only on income and dividends, but also on business sectors, meaning that the sectoral allocation of resources is distorted by differences in tax rates,

For example, as a result of Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States (26) (hereinafter the Cross-border Interest and Royalty Payments Directive) and Council Directive 2003/123/EC of 22 December 2003 amending Directive 90/435/EEC on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (27) (hereinafter the Parents-Subsidiary Directive), the tax treatment of dividends, interests or royalties may differ according to whether the payment is ma ...[+++]de to a domestic or a foreign company.

Another issue that needs to be addressed concerns differences in national legal provisions affecting corporate action processing, such as discrepancies in Member States' laws as to the determination of the exact moment when a purchaser is considered to be the owner of a security, e.g., for the payment of dividends.

(b) Where that amount exceeds the amount of dividends already received or the payment of which can be claimed, the amount of the difference must be placed in a reserve which cannot be distributed to shareholders.

Problems such as the current system of VAT, transfers between two companies in the same group, different tax rates between Member States (e.g. on dividends) and others act as a strong disincentive to cross-border commitments in the internal market.