ACCA P4考試：International Dividend Policy

1 Tax Planning

If the parent company has a subsidiary located overseas then it must consider the tax cost of repatriating profits in the form of a dividend.

Assuming that the subsidiary has not been established in a "tax haven" its profits will be subject to local corporate tax. In addition, on payment of a dividend, it may also have to deduct withholding tax.

Under double tax treaties the parent receiving the dividend will usually be entitled to offset the tax paid overseas against its eventual tax liability on the dividend.

However there may be limited or even no liability in the hands of the parent, either because the dividend is not treated as taxable income in the parent's country, or because the parent has tax allowable deductions which reduce the taxable amount.

Therefore the group may suffer overseas tax that cannot be recovered.

A possible solution to this problem is to establish an offshore sub-holding company between overseas subsidiaries and the ultimate parent. This can in fact lead to three potential tax benefits:

Increased double tax relief—the use of an offshore "mixer" company can increase credits for double tax relief by combining dividends from high and low taxed subsidiaries before they are paid up to the parent.

Capital gains tax protection—if the holding company is established in an appropriate jurisdiction any gains on the sale of the subsidiary may avoid tax.

Withholding tax minimisation—in certain cases the careful use of an offshore holding company can reduce the withholding tax burden compared to direct repatriation of income from the subsidiary to parent.

2 Management of Blocked Remittances

If a multinational company finds that remittances are blocked, it may have to consider other methods of transferring profit from the overseas subsidiary to the parent company.

Manipulation of transfer prices for goods or services supplied by the parent to the subsidiary. However, either the host country and⁄or the parent's jurisdiction may require the transfer price to be set at "arm's length" which may limit the amount of profit that can be extracted using this method.

Charging management fees from the parent company to the subsidiary. This may be easier to justify in the early years of investment but more difficult in later years if local managers have replaced expatriates.

Royalty payments or licence fees for the use of patents or intellectual capital owned by the parent. This method can be particularly flexible in the "new economy" where fees for human capital are more subjective than for physical goods.

Financing the overseas subsidiary with loans from the parent company and hence extracting profits in the form of interest as opposed to dividends.

However, each of the above methods must be carefully reviewed before implementation for their potential to expose the firm to:

Reputational risk: Ethical investors may dump the parent company's shares if it is suspected of circumventing overseas regulations. Furthermore, consumers may boycott its products.

Political risk: The host government may react aggressively to schemes and potentially appropriate its assets.