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if a U.S MNC company Sigma is thinking of establishing a subsidiary in Spain or Italy but want the location with the lowest tax liability.

if a U.S MNC company Sigma is thinking of establishing a subsidiary in Spain or Italy but want the location with the lowest tax liability. Sigma intends to repatriate all after tax foreign source income to the U.S.THE corporate income in the U.S is taxed at 35%. however, Spain. marginal corporate tax is 10% and Italy corporate income is taxed at 30%. the withholding tax treaty rates with the U.S on dividend income paid is 5% from Spain and 10% from Italy. what is the total tax liability for each country?

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