Cahiers de Droit Fiscal International (IFA CAHIERS Volume 85b)

Stock options, phantom stock plans, profit sharing plans, and other forms of deferred payments of emoluments are increasingly used as incentives for high-ranking and middle-class managers, mainly for internationally operating enterprises, but also by smaller firms. Some countries have enacted highly sophisticated systems of regulations dealing with the problems of the taxation of deferred remunerations. Other countries facing these new problems tried to solve them by applying general principles of taxation. There is great variety concerning the moment of the taxation of the employee and the deductibility of costs for the employer within the countries. Some countries treat deferred remunerations as pensions under special conditions. Timing problems and different qualifications under double tax agreements lead to international problems of double taxation and non-taxation.