International Tax Law and Profit Repatriation Strategies for Investments in Foreign Subsidiaries

Abstract This study is assigned to international tax law. It elaborates on various innovative strategies for tax-optimized profit repatriation from foreign subsidiaries. As an example, the analysis is carried out against the background of the country constellation USA/European Union. However, the results and strategies can be applied to other country constellations. The elaboration of profit repatriation strategies solves a significant taxation problem for investments in foreign subsidiaries, namely the incurrence of withholding tax in the subsidiary's foreign country of residence. At the same time, a contribution is made to expanding the literature. Tax effective profit repatriation strategies regarding investments in foreign subsidiaries have hardly been derived and discussed in the literature.