You are a MNC called Sigma corporation and youre contemplating establishing a wholly owned subsidiary operation in the Mediterranean. 2 countries under consideration are Spain and Cyprus. Sigma interns to repatriate all after-tax foreign-source income to the United States. In the United States corporate income is taxed at 35%. In Cyprus the marginal corporate tax rate is 10% and in Spain corporate income is taxed at 30%. The withholding tax treaty rates with the United States on dividend income paid is 5% from Cyprus and 10% from Spain. The financial manager of Sigma has asked you to hep him 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.

1. Show the total tax due from both Cyprus and Spain-which is the better choice?

2. 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.

3. What are 3 basic types of taxation that governments levy witching their tax jurisdictions?