This article discusses the income tax considerations relevant to a decision to incorporate a business abroad. The article provides an overview of some of the more important aspects of the corporate income tax laws of France, the Federal Republic of Germany, and the United Kingdom. The provisions of the countries' respective tax codes are contrasted and compared; included in this comparison are analogous provisions contained in the Internal Revenue Code of the United States. Due to the ever-changing character of the provisions of the countries' respective tax codes, this article is not an exhaustive study of any one country's tax laws or the policies underlying those laws. Rather, this article is a framework for review of the tax considerations relevant to a determination to incorporate a business in one of the named countries and highlights some of the distinctions and similarities between the countries' corporate income tax laws.
Francene M. Augustyn,
A Primer for Incorporating under the Income Tax Laws of France, Germany, or the United Kingdom,
Nw. J. Int'l L. & Bus.