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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.
Thomas Kollruss (Thu,) studied this question.