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
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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.