Capital export neutrality

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Capital export neutrality is a term used in finance. It is used in the field of international taxation. The term goes back to the German-American economist Richard Abel Musgrave .

Capital export neutrality exists when an investor , regardless of the country in which he invests his capital, is charged the same tax rate and can thus generate the same net return everywhere. Capital export neutrality is usually achieved through the country of residence principle: the investor must pay tax on his income in his country of residence. No matter where he invests, the same tax rate always applies. The place / scope of his investment decision is not influenced by taxes. In contrast to capital export neutrality, capital import neutrality guarantees that all investments are treated equally in a country. This is guaranteed by the source country principle. The tax is levied in this case is not the country of residence, but in the source country. All investors in a country, regardless of where they are resident, are subject to the same (withholding) tax rate. The investment decision is not influenced by where the investor comes from.

Capital export neutrality can only be guaranteed if the tax authorities align the taxation of capital gains abroad with those domestically. This requires the equal treatment of distributed and undistributed income.

Individual evidence

  1. Märkt, Jörg, 1970-, Schick, Gerhard, 1972-: International tax competition . Mohr Siebeck, Tübingen 2000, ISBN 3-16-147457-0 , p. 64 .
  2. Führich, Gregor J .: The influence of the ECJ case law on German corporate taxation - a tax planning and tax systematic analysis . Gabler Verlag / GWV Fachverlage GmbH, Wiesbaden, Wiesbaden 2009, ISBN 978-3-8349-1734-8 , pp. 6 .
  3. Märkt, Jörg, 1970-, Schick, Gerhard, 1972-: International tax competition . Mohr Siebeck, Tübingen 2000, ISBN 3-16-147457-0 , p. 65 .