Cahiers De Droit Fiscal International Interest Deductibility The Implementation Of Beps Action 4
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Cahiers De Droit Fiscal International Interest Deductibility The Implementation Of Beps Action 4
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Author : J.R. Gadwood
language : en
Publisher:
Release Date : 2019
Cahiers De Droit Fiscal International Interest Deductibility The Implementation Of Beps Action 4 written by J.R. Gadwood and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with categories.
For multinational businesses, one of the most controversial reports from the OECD BEPS project focused on limiting base erosion involving interest deductions and other financial payments. The report's departure from the arm's-length standard and adoption of mechanical approaches to limiting interest deductions aroused a great deal of concern. On the other hand, it was widely recognised that interest deductions offered the most straightforward option for those seeking to achieve base erosion and profit shifting. Although the OECD report characterised its recommendations as a best-practice approach rather than a minimum standard, there was an expressed expectation that domestic rules regarding interest limitations would "converge through the implementation of the agreed common approaches." Recognising that domestic law continues to evolve, Subject 1 of the 2019 Cahiers analysed 40 branch reports and aimed to determine whether this convergence expectation has borne out to date.
Cahiers De Droit Fiscal International
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Author : International Fiscal Association. Congress
language : en
Publisher:
Release Date : 2019
Cahiers De Droit Fiscal International written by International Fiscal Association. Congress and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with categories.
This book provides the general reports, EU reports and summary and conclusions of all branch reports of the 73rd Congress of the International Fiscal Association (IFA) held in London in 2019.
Interest Deductibility
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Author : International Fiscal Association. Congress
language : en
Publisher:
Release Date : 2019
Interest Deductibility written by International Fiscal Association. Congress and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with Income tax deductions for interest categories.
Applying The Arm S Length Principle To Intra Group Financial Transactions
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Author : Robert Danon
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-08-29
Applying The Arm S Length Principle To Intra Group Financial Transactions written by Robert Danon and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-08-29 with Law categories.
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
A Guide To The Anti Tax Avoidance Directive
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Author : Werner Haslehner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2020-06-26
A Guide To The Anti Tax Avoidance Directive written by Werner Haslehner and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-06-26 with Law categories.
This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.
Corporate Taxation Group Debt Funding And Base Erosion
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Author : Gianluigi Bizioli
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-02-07
Corporate Taxation Group Debt Funding And Base Erosion written by Gianluigi Bizioli and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-02-07 with Law categories.
The EU’s Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD’s Base Erosion and Profit Sharing project (BEPS) and the EU’s Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States—Germany, Italy, Spain and The Netherlands—as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.
European Union Corporate Tax Law
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Author : Christiana HJI Panayi
language : en
Publisher: Cambridge University Press
Release Date : 2021-06-17
European Union Corporate Tax Law written by Christiana HJI Panayi and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-17 with Business & Economics categories.
What is the impact of European Union law on Member State corporate tax systems and the cross-border activities of companies?
Limiting Base Erosion
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Author : Erik Pinetz
language : en
Publisher: Linde Verlag GmbH
Release Date : 2017-08-30
Limiting Base Erosion written by Erik Pinetz and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-08-30 with Law categories.
Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.
State Aid Law And Business Taxation
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Author : Isabelle Richelle
language : en
Publisher: Springer
Release Date : 2016-10-18
State Aid Law And Business Taxation written by Isabelle Richelle and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-10-18 with Law categories.
This book is a compilation of contributions exploring the impact of the European Treaty provisions regarding state aid on Member States’ legislation and administrative practice in the area of business taxation. Starting from a detailed analysis of the European Courts’ jurisprudence on Art.107 TFEU the authors lay out fundamental issues – e.g. on legal concepts like “advantage”, “selectivity” and “discrimination” – and explore current problems – in particular policy and practice regarding “harmful” tax competition within the European Union. This includes the Member States’ Code of Conduct on business taxation, the limits to anti-avoidance legislation and the options for legislation on patent boxes. The European Commission’s recent findings on preferential “rulings” are discussed as well as the general relationship between international tax law, transfer pricing standards and the European prohibition on selective fiscal aids.
Limiting Base Erosion Involving Interest Deductions And Other Financial Payments Action 4 2016 Update
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Author : Organization for Economic Cooperation and Development
language : en
Publisher: Organization for Economic Co-Operation & Development
Release Date : 2016-12-15
Limiting Base Erosion Involving Interest Deductions And Other Financial Payments Action 4 2016 Update written by Organization for Economic Cooperation and Development and has been published by Organization for Economic Co-Operation & Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-12-15 with Corporations categories.
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).