Download Corporate Loss Utilisation through Aggressive Tax Planning by OECD PDF

By OECD

Company losses elevate compliance dangers if competitive tax making plans is used as a method of accelerating or accelerating tax aid in methods no longer meant via the legislator, or to generate synthetic losses. This file describes the dimensions of loss carry-forwards, the principles acceptable relating to losses, and identifies the next probability parts: company reorganisations, monetary tools and non-arms size move pricing. After having summarised competitive tax making plans schemes on losses, in addition to nation detection and reaction thoughts, it bargains a couple of conclusions and advice for tax management and tax coverage officers.   Table of content material :Foreword AbbreviationsExecutive precis IntroductionChapter 1. measurement of company Tax Losses bankruptcy 2. coverage concerns within the Tax therapy of Losses bankruptcy three. state principles on company Tax Losses bankruptcy four. Schemes related to Tax Losses bankruptcy five. concepts for Detecting Schemes related to Tax LossesChapter 6. suggestions for Responding to Schemes regarding Tax Losses Conclusions and RecommendationsReferencesAnnex A. Graphs displaying measurement of loss hold forwards in comparison to loss hold forwards as a percent of GDP for ten nations

Show description

Read Online or Download Corporate Loss Utilisation through Aggressive Tax Planning PDF

Best development & growth books

Uganda's Economic Reforms: Insider Accounts

Following the fifteen years rule of Idi Amin, struggle and civil conflict, the Ugandan economic climate was once in ruins by the point peace was once restored in 1986. due to the fact that then Uganda has constantly been one of many quickest growing to be economies in Africa, resulting in a considerable aid in poverty. Its monetary luck has attracted significant consciousness and has arguably had extra effect on improvement considering and at the foreign reduction structure than the other kingdom.

International Assistance to the Palestinians after Oslo: Political Guilt, Wasted Money (Routledge Studies on the Arab-Israeli Conflict)

Why has the West allotted vertiginous sums of cash to the Palestinians after Oslo? What were donors’ motivations and specially the political results of the money spent? in response to unique educational learn and primary hand proof, this e-book examines the interface among international relations and foreign tips throughout the Oslo years and the intifada.

Price and Nonprice Rivalry in Oligopoly: The Integrated Battleground

The speculation of fee and caliber selection making in industries with a number of organizations which realize their mutual interdependence is of accelerating curiosity to economists and coverage makers. This publication introduces a idea of that call making, established upon the thought of the as a group of brokers who're all in favour of either aggressive and co-operative relationships.

Additional resources for Corporate Loss Utilisation through Aggressive Tax Planning

Example text

12. In New Zealand losses can be carried forward after an internal group restructuring if continuity and commonality requirements are met. 13. Special rules apply to the petroleum sector: carry forward of losses with interest; tax value of losses refundable on cessation of activity; tax value of losses due to exploration refundable annually. 14. In case of liquidation a two-year loss carry-back is allowed. In addition, a temporary two-year loss carry-back has been introduced for losses from 2008 and 2009.

Although the Explanatory Memorandum only refers to dual resident companies, the wording of the statute itself may also cover other cases, including certain cases involving hybrid entities. The hybrid entity cases that may be covered are cases in which the controlling entity (in particular, a German GmbH) is a corporation for German tax purposes but transparent or disregarded for foreign tax purposes. Whether such cases are covered by the rule is a subject of debate in the German tax literature.

Section 5G of the Tax Assessment Law. 14. Section 14(1) No. 5 of the German Corporation Tax. 15. Government draft Gesetzentwurf der Bundesregierung Entwurf eines Gesetzes zur Fortentwicklung des Unternehmensteuerrechts of 10 September 2001, Bundestags-Drucksache 14/6882 p. 37. pdf (as on 29 June 2009). Although the Explanatory Memorandum only refers to dual resident companies, the wording of the statute itself may also cover other cases, including certain cases involving hybrid entities. The hybrid entity cases that may be covered are cases in which the controlling entity (in particular, a German GmbH) is a corporation for German tax purposes but transparent or disregarded for foreign tax purposes.

Download PDF sample

Rated 4.15 of 5 – based on 5 votes