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Corporate Loss Utilisation through Aggressive Tax Planning

Corporate Loss Utilisation through Aggressive Tax Planning PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264119221
Category :
Languages : en
Pages : 92

Book Description
After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.

Corporate Loss Utilisation through Aggressive Tax Planning

Corporate Loss Utilisation through Aggressive Tax Planning PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264119221
Category :
Languages : en
Pages : 92

Book Description
After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.

Corporate Loss Utilisation through Aggressive Tax Planning

Corporate Loss Utilisation through Aggressive Tax Planning PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9789264119215
Category :
Languages : en
Pages : 92

Book Description
After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.

Addressing Base Erosion and Profit Shifting

Addressing Base Erosion and Profit Shifting PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264192743
Category :
Languages : en
Pages : 91

Book Description
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Income Tax Treatment of Cooperatives: Handling of losses

Income Tax Treatment of Cooperatives: Handling of losses PDF Author: Donald A. Frederick
Publisher:
ISBN:
Category : Agricultural industries
Languages : en
Pages : 108

Book Description


Co-operative Compliance: A Framework From Enhanced Relationship to Co-operative Compliance

Co-operative Compliance: A Framework From Enhanced Relationship to Co-operative Compliance PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264200851
Category :
Languages : en
Pages : 110

Book Description
This report examines the relationship between large business taxpayers and revenue bodies, five years on from the publication of the FTA’s Study into the Role of Tax Intermediaries.

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots PDF Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 148436399X
Category : Business & Economics
Languages : en
Pages : 45

Book Description
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

Interpretation and Application of Tax Treaties in North America

Interpretation and Application of Tax Treaties in North America PDF Author: Juan Angel Becerra
Publisher: IBFD
ISBN: 9087220197
Category : Canada
Languages : en
Pages : 299

Book Description
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.

Policy Framework for Investment, 2015 Edition

Policy Framework for Investment, 2015 Edition PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264208666
Category :
Languages : en
Pages : 138

Book Description
The objective of the Policy Framework for Investment (PFI) is to mobilise private investment that supports steady economic growth and sustainable development, contributing to the economic and social well-being of people around the world.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264218815
Category :
Languages : en
Pages : 103

Book Description
This report, produced by the OECD/G20 Project on Base Erosion and Profit Shifting sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements.

Shipowners' Limitation of Liability

Shipowners' Limitation of Liability PDF Author: Miguel Correia
Publisher: Kluwer Law International B.V.
ISBN: 9041148485
Category : Law
Languages : en
Pages : 391

Book Description
This book refines the features of a variety of different common law and civil law systems down to a recognizable standard CIT system, identifying in the process the system’s core strengths and problems, as well as the factors that determine its impact on corporate behavior. The author offers insightful perspectives on such crucial issues as the following: corporate group members versus corporate groups as taxable entities; anti-abuse rules and developments in judicial anti-abuse doctrines; costs associated with, e.g., valuation of assets, compliance, and administration; how certain core CIT concepts are independent of tax law; efficiency, equity, and the protection of existing property rights; the firm’s reaction to behavioral control instruments; limitations on the use of losses; depreciation and amortization rules; manipulation of legal characterization; and transfer of assets and income. The work has an interdisciplinary approach drawing on the literatures of tax law, economics, corporate law, accounting, and business management. It concludes with a set of policy guidelines that should be considered when approaching the traditionally cumbersome interaction between tax systems and corporate groups. Especially valuable to the practitioner are the book’s extensive graphic design solutions illustrating the subtleties of the operation of corporate tax laws. Analyzing the taxation of corporate groups in a user-friendly form not available in any other source, this book greatly enhances the development of advanced tax planning methods that do not disrupt the economic operation of businesses. Its comprehensive conceptual framework will greatly facilitate the work of those, from practitioners to researchers, interested in developing a practical approach to corporate income taxation applicable at a global level.