Double taxation: When it applies and how companies reduce its impact

Tax
Tax

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Mehr erfahren 
  1. Einführung
  2. What is double taxation?
  3. When does double taxation happen in business?
    1. Corporate profits distributed to owners and investors
    2. Business income earned across borders
    3. Layered ownership structures
  4. Why are corporations often affected by double taxation?
  5. How does double taxation apply to cross-border income?
  6. How do tax credits reduce double taxation?
    1. Foreign tax credits
    2. Credit caps and limits
  7. How do tax treaties prevent double taxation?
  8. How Stripe Tax can help

Double taxation can affect a business’s tax bill, especially as companies grow or operate across borders. Double taxation happens when the same income is taxed more than once, usually through corporate tax structures or international tax rules. Understanding how this works is essential to making informed decisions about your company’s structure, expansion, and compliance.

Below, we’ll explain what double taxation is, why it occurs in business, and how tax credits and international tax treaties are designed to reduce its impact.

What’s in this article?

  • What is double taxation?
  • When does double taxation happen in business?
  • Why are corporations often affected by double taxation?
  • How does double taxation apply to cross-border income?
  • How do tax credits reduce double taxation?
  • How do tax treaties prevent double taxation?
  • How Stripe Tax can help

What is double taxation?

Double taxation is when the same income is taxed more than once.

The first type of double taxation is corporate double taxation. A company earns profits and pays corporate income tax on those profits. If the company then distributes those profits to shareholders as dividends, the shareholders pay tax on that same income at the individual level.

The second is international double taxation. One country could tax income because it was earned within its territory. Another country could tax that same income because the company or individual earning it is considered a resident there.

When does double taxation happen in business?

Double taxation tends to happen when income moves between entities, owners, or countries. Tax systems often assert taxing rights based on residency, source of income, or both. When those rules overlap, the same income can fall into two tax nets at once.

Here are some common situations where double taxation happens.

Corporate profits distributed to owners and investors

A corporation pays corporate income tax on its profits, and when those profits are paid out as dividends, shareholders pay tax again at the individual level on the same earnings. The duplication exists because the company and its owners are treated as separate taxpayers, even though the income originated once. Earnings from equity investments can also be taxed at the corporate level when profits are generated and again when those profits are distributed or realized by investors.

Business income earned across borders

Income generated in one country could be taxed there, and then taxed again by the country where the business or individual has its headquarters. This is one common cause of double taxation for companies operating internationally. One country could also treat an entity or income type differently from another, leading both to tax the same income under different rules.

Layered ownership structures

When income flows through multiple legal entities (for example, subsidiaries, holding companies, or investment vehicles), it can be taxed at more than one level if relief mechanisms aren’t properly applied or available. Each entity could be viewed as independently taxable, even when the income stream is economically continuous.

Why are corporations often affected by double taxation?

Corporations are especially exposed to double taxation because the tax system treats them as independent legal and economic actors.

A corporation pays tax on its profits as its own legal entity, regardless of what happens to those profits afterward. Many tax systems were designed around the idea that corporations should be taxed independently to reflect their size, permanence, and ability to accumulate capital.

When profits are later distributed to shareholders, they’re treated as taxable income at the individual level. Dividends are considered income to a separate taxpayer, which creates another round of taxation on the same earnings.

While some business structures, known as pass-through entities, allow income to flow directly to owners without entity-level tax, traditional corporations do not qualify for that treatment. Limited liability companies (LLCs) and S corps, on the other hand, are generally treated as pass-through entities. Choosing a corporate structure often means accepting a second tax layer in exchange for benefits such as limited liability and access to capital markets.

Even where systems attempt to soften double taxation through reduced dividend rates or credits, those measures are often incomplete or uneven. The result is that corporate income is often taxed more than once across all contexts. When shareholders are located in different countries from the corporation, dividend income can face withholding taxes abroad and personal income taxes at home. Although treaties or foreign tax credits can reduce this burden, the income could still be taxed more than once.

How does double taxation apply to cross-border income?

When income moves between countries, multiple jurisdictions can claim the right to tax it.

Many countries tax income when economic activity happens within their borders, a so-called nexus. Source-based taxation can be triggered by local sales, operations, or employees. Some countries tax worldwide income earned by a resident business or individual. When source-based and residence-based taxation overlap, the same income can be taxed twice unless relief is applied.

Many countries limit the taxation of foreign businesses unless they are considered a permanent establishment. When a specific threshold is met (subject to jurisdiction), profits attributable to that presence can be taxed locally, increasing the risk of double taxation if residence rules also apply.

Cross-border payments such as dividends, interest, or royalties are often subject to withholding tax in the source country. Those payments could still be taxed again in the recipient’s home country if credits or exemptions aren’t available. Countries could also recognize income at different times or classify it differently. Even when relief exists, mismatches can create temporary double taxation or compliance issues.

How do tax credits reduce double taxation?

Tax credits can help neutralize the overlap of multiple tax systems. Businesses often experience the double tax from a cash-flow and compliance perspective before it’s mitigated.

Here’s how tax credits work.

Foreign tax credits

Foreign taxes are credited against domestic tax liability. A tax credit allows foreign tax to be applied against the tax owed at home on the same income. This keeps the total tax paid closer to what would apply if the income were taxed only once. Unlike deductions, which reduce taxable income, credits reduce the tax bill itself. That distinction generally makes credits more effective at offsetting double taxation.

While commonly associated with income tax, credits can also apply to withholding taxes on dividends, interest, and royalties, which are typically treated as income taxes paid at the source. This is especially relevant for cross-border cash flows.

Credit caps and limits

Systems typically limit credits to the amount of domestic tax that would have been owed on the foreign income. This prevents credits from being used to offset unrelated taxes while generally reducing or eliminating double taxation on the same income base. Credits typically require proof that foreign tax was actually paid and that the income matches what’s being reported domestically. Mismatches in timing or classification can delay relief.

Businesses and individuals can face different credit limitations and eligibility rules, even when the income source is the same. Multinational companies often manage credits across multiple entities and jurisdictions at once.

How do tax treaties prevent double taxation?

Tax treaties set shared rules between countries so the same income isn’t taxed twice simply because it crosses a border.

Here’s how tax treaties help mitigate double taxation:

  • Taxing rights are allocated between countries: Treaties define which country has the primary right to tax specific types of income, such as business profits, dividends, interest, or royalties. This reduces overlap.

  • Permanent establishment thresholds are standardized: Treaties establish when a business presence is substantial enough to justify taxation in a source country.

  • Withholding taxes are reduced or eliminated: Many treaties cap or remove withholding taxes on cross-border payments such as dividends and income.

  • Relief methods are mandated: Treaties require one country to provide relief, often through tax credits or exemptions, when the other country taxes the income.

  • Dispute resolution mechanisms are included: When countries disagree on how income should be taxed, treaties provide formal processes for resolving those disputes. This protects businesses from being taxed inconsistently by multiple authorities.

  • Consistency improves long-term planning: Because treaties are stable and bilateral, companies can structure operations and pricing with clearer expectations about how income will be taxed.

How Stripe Tax can help

Stripe Tax reduces the complexity of tax compliance so you can focus on growing your business. Stripe Tax helps you monitor your obligations and alerts you when you exceed a sales tax registration threshold based on your Stripe transactions. In addition, it automatically calculates and collects sales tax, VAT, and GST on both physical and digital goods and services—in all US states and in more than 100 countries.

Start collecting taxes globally by adding a single line of code to your existing integration, clicking a button in the Dashboard, or using our powerful API.

Stripe Tax can help you:

  • Understand where to register and collect taxes: See where you need to collect taxes based on your Stripe transactions. After you register, switch on tax collection in a new state or country in seconds. You can start collecting taxes by adding one line of code to your existing Stripe integration or add tax collection with the click of a button in the Stripe Dashboard.

  • Register to pay tax: Let Stripe manage your global tax registrations and benefit from a simplified process that prefills application details—saving you time and simplifying compliance with local regulations.

  • Automatically collect tax: Stripe Tax calculates and collects the right amount of tax owed, no matter what or where you sell. It supports hundreds of products and services and is up-to-date on tax rules and rate changes.

  • Simplify filing: Stripe Tax seamlessly integrates with filing partners, so your global filings are accurate and timely. Let our partners manage your filings so you can focus on growing your business.

Learn more about Stripe Tax, or get started today.

Der Inhalt dieses Artikels dient nur zu allgemeinen Informations- und Bildungszwecken und sollte nicht als Rechts- oder Steuerberatung interpretiert werden. Stripe übernimmt keine Gewähr oder Garantie für die Richtigkeit, Vollständigkeit, Angemessenheit oder Aktualität der Informationen in diesem Artikel. Sie sollten den Rat eines in Ihrem steuerlichen Zuständigkeitsbereich zugelassenen kompetenten Rechtsbeistands oder von einer Steuerberatungsstelle einholen und sich hinsichtlich Ihrer speziellen Situation beraten lassen.

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