Taxation of Nonprofit Associations in an International Comparison

The objective of this study is an investigation of tax regulations for nonprofit associations (NPAs) in EU countries, Japan, and the United States. Following a brief description of qualification principles for NPAs, treatment of business units, or liability issues, a particular focus is put on a comparison of regulations concerning the taxation of current profits, inheritance, and gift taxes and the tax treatment of contributions and membership fees. In general, a strong similarity among the examined developed countries can be found for the different aspects considered, but significant differences also exist.