From Imputation to Exemption: Designing Corporate–Shareholder Integration for Cross-Border Investment in Open Economies

This article compares classical taxation, full imputation, shareholder relief and dividend exemption as methods of integrating corporate and shareholder taxation in respect of cross-border portfolio investment. Using doctrinal analysis and stylized rate-normalized illustrations drawn from Australia and European jurisdictions, it evaluates how each model performs against neutrality, efficiency, equity and international coordination once withholding taxes and residence-state relief are taken seriously. The article argues that, while full imputation performs well domestically, dividend exemption and well-calibrated shareholder relief travel better in open economies by reducing stranded tax, administrative complexity and discriminatory spillovers.