A domestic corporation in Japan is taxed on its worldwide income, including foreign branch income. However, 95% of dividends received by a domestic corporation from a foreign company in which it has held at least 25% (or lower, depending on the relevant
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Germany taxes its corporate residents on their worldwide income. However, most double tax treaties (DTTs) exempt income attributable to a foreign permanent establishment (PE). Non-residents with PE or property income are taxed by assessment on German-source income; those earning royalties and dividends
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A resident company is subject to corporate income tax (CIT) in France on its French-source income. In that respect, income attributable to foreign business activity (if there is no treaty in force between France and the relevant foreign country) or to a foreign
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All undistributed corporate profits are tax exempt. This exemption covers both active (e.g. trading) and passive (e.g. dividends, interest, royalties) types of income. It also covers capital gains from the sale of all types of assets, including shares, securities, and immovable property.
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