Comparative survey, covering double taxation agreements, conflict of laws, tax deferral, close and base companies, residence, abuse of legal forms, holding companies, group taxation, and the financing of foreign corporations, explained in the light of the different legal systems applied in Western Europe, Canada and the USA. The material states the law as of 30 November 1974.

The subject of this series of reports is the differences in tax treatment between a domestic subsidiary corporation and a domestic branch of a non-resident of foreign enterprise.