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INTERNATIONAL TAX RESEARCH MEMOMannring Co., a U.S. corporation, has decided to set up a headquarters subsidiary in Europe. Management has narrowed its location choice to…

INTERNATIONAL TAX RESEARCH MEMOMannring Co., a U.S. corporation, has decided to set up a headquarters subsidiary in Europe. Management has narrowed its location choice to either Spain, or Ireland, or Switzerland. The company has asked you to research some of the income tax implications of setting up a corporation in these three countries. In particular, management wants to know what tax rate will be imposed on corporate income earned in the country and the withholding rates applied to interest, dividends, and royalty payments from the subsidiary to the Mannring Co.To answer the tax rate question, consult KPMG’s Corporate and Indirect Tax Survey included as an attachment to the assignment.To answer the withholding tax questions, consult the treaties between the United States and Spain, Ireland, and Switzerland, which you can access at www.irs.gov (type in treaties as your search word)

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