Base Erosion by Intra-group Debt and BEPS Project Action 4's Best Practice Approach - a Case Study of Chevron PDF Download
Are you looking for read ebook online? Search for your book and save it on your Kindle device, PC, phones or tablets. Download Base Erosion by Intra-group Debt and BEPS Project Action 4's Best Practice Approach - a Case Study of Chevron PDF full book. Access full book title Base Erosion by Intra-group Debt and BEPS Project Action 4's Best Practice Approach - a Case Study of Chevron by A. Ting. Download full books in PDF and EPUB format.
Author: A. Ting Publisher: ISBN: Category : Languages : en Pages :
Book Description
It is well known that many multinational enterprises use intra-group debts for tax avoidance purposes. Action 4 of the OECD's Base Erosion and Profit Shifting (BEPS) project represents a recent major contribution to the literature on the subject, providing important insights into the design features and issues of different forms of interest limitation regimes in practice. At the other side of the world, a recent major tax case and the Senate enquiry into corporate tax avoidance in Australia revealed detailed information about how Chevron used intra-group debts in its tax structures, which is very difficult, if not impossible, to discern from its financial statement. It provides a timely case study of how intra-group debts are used in practice, setting the stage for an evaluation of Action 4's recommendations. This article first analyses two tax structures used by Chevron in Australia as a case study to highlight the key issues arising from intra-group debts. Secondly, using empirical data on Chevron, this article evaluates whether Action 4's recommendations are effective for addressing BEPS arising from intra-group debt.
Author: A. Ting Publisher: ISBN: Category : Languages : en Pages :
Book Description
It is well known that many multinational enterprises use intra-group debts for tax avoidance purposes. Action 4 of the OECD's Base Erosion and Profit Shifting (BEPS) project represents a recent major contribution to the literature on the subject, providing important insights into the design features and issues of different forms of interest limitation regimes in practice. At the other side of the world, a recent major tax case and the Senate enquiry into corporate tax avoidance in Australia revealed detailed information about how Chevron used intra-group debts in its tax structures, which is very difficult, if not impossible, to discern from its financial statement. It provides a timely case study of how intra-group debts are used in practice, setting the stage for an evaluation of Action 4's recommendations. This article first analyses two tax structures used by Chevron in Australia as a case study to highlight the key issues arising from intra-group debts. Secondly, using empirical data on Chevron, this article evaluates whether Action 4's recommendations are effective for addressing BEPS arising from intra-group debt.
Author: Krishen Mehta Publisher: Zed Books Ltd. ISBN: 1786998114 Category : Social Science Languages : en Pages : 290
Book Description
In the wake of the Panama Papers scandal and similar leaks, tax havens are now firmly in the spotlight. Today, roughly half of all global trade still passes through tax haven jurisdictions, costing millions in lost revenue to countries around the world. Such practices affect all of us, but are most keenly felt by poorer people in developing countries, where unfair tax practices have become a major obstacle to development, and which have allowed multinational corporations to continue to exploit developing economies. This collection argues that, for developing countries to achieve social justice and lasting prosperity, they must take control of their own tax destinies, and that this will also be crucial to achieving the Sustainable Development Goals. Covering such topics as natural resource management, representation in global tax institutions and effective strategies for building and protecting tax bases, the collection brings together expertise from a variety of countries and disciplines. It explores the options available to developing countries, and provides a basis for concerted action by tax authorities, policy makers, academics and civil society experts to design tax systems that can sustain a just society.
Author: Organization for Economic Cooperation and Development Publisher: Organization for Economic Co-Operation & Development ISBN: 9789264268326 Category : Corporations Languages : en Pages : 0
Book Description
The 2015 Report established a common approach which directly links an entity's net interest deductions to its level of economic activity, based on taxable earnings before interest income and expense, depreciation and amortisation (EBITDA).
Author: Dirk A. Zetzsche Publisher: Kluwer Law International B.V. ISBN: 9041149953 Category : Law Languages : en Pages : 948
Book Description
Apart from MiFID, the Alternative Investment Fund Managers Directive (AIFMD) may be the most important European asset management regulation of the early twenty-first century. In this in-depth analytical and critical discussion of the content and system of the directive, thirty-eight contributing authors – academics, lawyers, consultants, fund supervisors, and fund industry experts – examine the AIFMD from every angle. They cover structure, regulatory history, scope, appointment and authorization of the manager, the requirements for depositaries and prime brokers, rules on delegation, reporting requirements, transitional provisions, and the objectives stipulated in the recitals and other official documents. The challenging implications and contexts they examine include the following: – connection with systemic risk and the financial crisis; - nexus with insurance for negligent conduct; - connection with corporate governance doctrine; - risk management; - transparency; - the cross-border dimension; - liability for lost assets; - impact on alternative investment strategies, and - the nexus with the European Regulation on Long-Term Investment Funds (ELTIFR). Nine country reports, representing most of Europe’s financial centres and fund markets add a national perspective to the discussion of the European regulation. These chapters deal with the potential interactions among the AIFMD and the relevant laws and regulations of Austria, France, Germany, Italy, Luxembourg, Liechtenstein, The Netherlands, Malta and the United Kingdom. The second edition of the book continues to deliver not only the much-needed discussion of the inconsistencies and difficulties when applying the directive, but also provides guidance and potential solutions to the problems it raises. The second edition considers all new developments in the field of alternative investment funds, their managers, depositaries, and prime brokers, including, but not limited to, statements by the European Securities and Markets Authority (ESMA) and national competent authorities on the interpretation of the AIFMD, as well as new European regulation, in particular the PRIIPS Regulation, the ELTIF Regulation, the Regulation on European Venture Capital Funds (EuVeCaR), the Regulation on European Social Entrepreneurship Funds (EUSEFR), MiFID II, and UCITS V. The book will be warmly welcomed by investors and their counsel, fund managers, depositaries, asset managers, administrators, as well as regulators and academics in the field.
Author: International Monetary Fund Publisher: International Monetary Fund ISBN: 1451821190 Category : Business & Economics Languages : en Pages : 29
Book Description
This Selected Issues paper on Kenya reviews Kenya’s external stability in a context where the exchange rate has strengthened and capital inflows are playing an increasingly important role. Kenya’s external current account deficit has widened, reflecting strong import volumes as well as rising import prices, particularly for oil, but external debt as a percent of GDP has declined steadily. Underlying these developments have been a steady increase in capital inflows and a remarkable rebound of economic growth since 2003 after two decades of stagnation.
Author: OECD Publisher: Org. for Economic Cooperation & Development ISBN: 9789264241237 Category : Languages : en Pages : 186
Book Description
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
Author: Brigitte Unger Publisher: Oxford University Press ISBN: 0198854722 Category : Business & Economics Languages : en Pages : 369
Book Description
This is an open access title available under the terms of a CC BY-NC-ND 4.0 International licence. It is free to read at Oxford Scholarship Online and offered as a free PDF download from OUP and selected open access locations. Combating Fiscal Fraud and Empowering Regulators analyzes the impact of new international tax regulations on the scope and scale of tax evasion, tax avoidance, and money laundering. These are analyzed through an ecosystem framework in which, similar to a natural ecosystem, new tax regulations appear as heavy shocks to the tax ecosystem, to which the 'species' such as countries, corporations, and tax experts will react by looking for new loopholes and niches of survival. By analyzing the impact of tax reforms from different perspectives--a legal, political science, accounting, and economic one--one may derive an assessment of the reforms and policy recommendations for an improved international tax system. The ultimate goal is to combat fiscal fraud and empower regulators, in that line, this volume is intended for a broad audience that seeks to know more about the latest state of the art in the realm of taxation from a multidisciplinary perspective. The money involved amounts to billions in unpaid taxes that could be better used for stopping hunger, guaranteeing education, and safeguarding biodiversity, hence making this world a better one. Regulators can see this book as a guiding light of what has happened in the past forty years, and how the world has and will continue to change as a result of it. Combating Fiscal Fraud and Empowering Regulators is also a warning about new emerging tax loopholes, such as freeports or golden passports and visas, where residency can be bought in tax havens, even within the European Union. The main message is that inequality can and has to be reduced substantially and that this can be achieved through a well-working international tax system that eliminates secrecy, opaqueness, and tax havens.
Author: World Bank Publisher: World Bank Publications ISBN: 1464814953 Category : Business & Economics Languages : en Pages : 511
Book Description
Global value chains (GVCs) powered the surge of international trade after 1990 and now account for almost half of all trade. This shift enabled an unprecedented economic convergence: poor countries grew rapidly and began to catch up with richer countries. Since the 2008 global financial crisis, however, the growth of trade has been sluggish and the expansion of GVCs has stalled. Meanwhile, serious threats have emerged to the model of trade-led growth. New technologies could draw production closer to the consumer and reduce the demand for labor. And trade conflicts among large countries could lead to a retrenchment or a segmentation of GVCs. World Development Report 2020: Trading for Development in the Age of Global Value Chains examines whether there is still a path to development through GVCs and trade. It concludes that technological change is, at this stage, more a boon than a curse. GVCs can continue to boost growth, create better jobs, and reduce poverty provided that developing countries implement deeper reforms to promote GVC participation; industrial countries pursue open, predictable policies; and all countries revive multilateral cooperation.
Author: A. Ting
Author: A. Ting
Author: Krishen Mehta
Author: Peter Harris
Author: Organization for Economic Cooperation and Development
Author: United Nations
Author: Dirk A. Zetzsche
Author: International Monetary Fund
Author: OECD
Author: Brigitte Unger
Author: World Bank