Most governments of high income countries stimulate domestic philanthropy. For philanthropy crossing borders, however, governments are less consentient. These varying standpoints are reflected in the tax legislation of countries. In many of the countries concerned, donations to domestic charitable causes are rewarded with a tax incentive. When a donation crosses borders, however, the tax incentive does not always apply.
This article examines the different approaches governments hold towards the application of tax incentives in cross-border situations and the underlying rationales. An overview of the legislation regarding cross-border donations in Australia, Barbados, Belgium, France, Germany, Hungary, Japan, the Netherlands, Spain, Sweden, the United Kingdom and the United States is given. Through the analysis of the relevant tax sources, tax jurisdictions are classified into four common models that summarize the spectrum of different approaches governments hold. They vary from jurisdictions that support cross-border donations with a tax incentive to governments that restrict tax incentives to donations within the country and two models that represent the more moderate approaches between these extremes.
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