Asymmetrische Besteuerung unter Ausschüttungsbeschränkungen

Abstract

Besides the importance of tax accounting rules for the corporation's tax burden, reporting conventions determine the shareholders' personal tax payments for the dividends received. Taxation may affect investment or financing decisions under different tax accounting and financial reporting rules. There are for example different depreciation schedules or different accruals shifting the tax base over time. Further, capital formation will differ under uniform or separate reporting. Under uncertainty loss offsetting rules are very important for defining a tax base which is neutral according to investment decisions. Constraints for loss offsetting cause tax law asymmetries and may disturb investment decisions. Most tax laws set constraints for loss offsetting when abandoning an investment project. The paper shows for three different reporting conventions that the risk for tax law asymmetries is not the same under these reporting conventions at the time of abandonment.