Part II Economic Regulation by Home and Host Countries, 7 Taxation Problems Associated with MNEs

As in the case of a purely domestic company, the principal aim behind the taxation of MNEs is to collect revenue on the undistributed profits of the company and upon the distributions of profits made to shareholders, in accordance with the rules applicable to the taxing jurisdiction concerned.1 However, the taxation of MNEs involves further issues arising out of the internationally integrated operations of the firm, the legal relations between its affiliates, and the territorial limits of national revenue laws. Of the many tax issues relevant to MNEs,2 this...