Apple is contemplating establishing a wholly-owned subsidiary operation in the Mediterranean. Two countries under consideration are Spain and Cyprus. Sigma intends to repatriate all after-tax foreign-source income to the United States. In the United States, corporate income is taxed at 35 percent. In Cyprus, the marginal corporate tax rate is 30 percent; however, in Spain corporate income is taxed at 15 percent. The withholding tax treaty rates with the United States on dividend income paid is 5 percent from Cyprus and 10 percent from Spain. The CEO has asked you to help her determine where to locate the new subsidiary. The location decision of Cyprus or Spain will be based on which country has the smaller total tax liability.

Show that the total tax due from both Cyprus and Spain and then make your recommendation for the better choice. Also, show how double taxation on a taxpayer may result if all countries were to tax the worldwide income of their residents and the income earned within their territorial boundaries. Lastly, mention the 3 basic types of taxation that governments levy within their tax jurisdictions.