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Author: Kristina Murphy
Publisher:
ISBN: 9780642768247
Category : Tax planning
Languages : en
Pages :
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Book Description
Author: Kristina Murphy
Publisher:
ISBN: 9780642768247
Category : Tax planning
Languages : en
Pages :
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Book Description
Author: OECD
Publisher: OECD Publishing
ISBN: 9264119221
Category :
Languages : en
Pages : 92
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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.
Author: Edward Mendlowitz
Publisher: Simon & Schuster Books For Young Readers
ISBN:
Category : Business & Economics
Languages : en
Pages : 200
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Book Description
Author: P. Piantavigna
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Multinational enterprises make use of aggressive tax planning strategies because they are able to operate in the legal vacuum that exists between nation states. The tax burden is not mitigated by falsifying the facts of tax-relevant events (as in the case of tax evasion) or through simulation of certain transactions (as in the case of sham), but through careful use of existing gaps between tax rates. This article describes the current situation with normative gaps in global taxation and erosion of national governance due to the loss of sovereignty and the extraterritorial application of national law. It is argued that a legal vacuum represents a substantial cost for nation states. To reduce this cost, the current international proposals are considered. The article aims to clarify whether and to what extent the BEPS Project has contributed to redefining the concept of "legal vacuum" in the international tax system. In particular, the question is whether, in order to prevent aggressive tax planning schemes, OECD member states are required to avoid situations of double non-taxation and cases of no or low taxation associated with practices that artificially segregate taxable income from the generating activities.
Author: Paul Eisenberg
Publisher: GRIN Verlag
ISBN: 3668875928
Category : Business & Economics
Languages : en
Pages : 86
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Book Description
Document from the year 2014 in the subject Business economics - Law, grade: Overall Degree 1,3, University of Linz, language: English, abstract: This work focuses on the Commission Recommendation of 06.12.2012 on aggressive tax planning C(2012) 8806 final. It aims to analyse the concepts and definitions underlying the Recommendation, its legal basis and its impact on the EU, international, academic and professional debate about aggressive tax planning. The discussion works through a thorough literature review covering primary and secondary EU law, ECJ jurisprudence, political announcements of the OECD and other international organisations. Detailed tables summarise the key issues discovered. The Recommendation has been neither unanimously adopted, nor rejected by the public. It provides broad definitions already addressed in a more precise manner in other official publications. Its approach against double non-taxation is similar to that of the ECJ and its GAAR proposal has gained ground with regard to the recent OECD announcements. The main criticism arises from the academia: the Recommendation is considered to be too general and to deviate widely from the established methodologies. The scope of the Recommendation lies on direct taxation of business activity which precludes analysis of indirect taxes as well as statutory wrongs like harmful tax competition or state aid. The study enriches the academic publicity on the Recommendation that has experienced only modest coverage by the taxation scholarship following its release.
Author: E. Gil García
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
This article analyses the reinforcement of the substance requirement in the current international standards. Due to globalization and complex business structures, countries have implemented measures to prevent base erosion and profit shifting (BEPS). Action Plans promoted by the OECD and EU are used globally to tackle harmful tax practices that allow multinational groups to carry out "aggressive" tax planning.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264192743
Category :
Languages : en
Pages : 91
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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.
Author: F. Cachia
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Courts in many countries have found that the tax laws should be interpreted so as to prevent their avoidance by the use of transactions that have no business purpose. This goes to say that the lack of a proper business motive or transactions which do not reflect the economic reality may be interpreted as a step further to tax avoidance and therefore leads to aggressive tax planning (ATP). The European Commission (EC) launched a public consultation on 10 November 2016 to gather feedback on the way forward for EU action on advisers and intermediaries who facilitate tax evasion, tax avoidance and aggressive tax planning. Following the EC's public consultation, the EC published a tax paper entitled the Study on Structures of Aggressive Tax Planning and Indicators, highlighting the model ATP structures and identifying ATP indicators which facilitate or allow ATP. This article examines the said tax paper by selecting the most prevalent ATP structures and how these are countered though the EC's Anti-Tax Avoidance Package.
Author: Andrew M. Bauer
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In measuring tunneling with inter-corporate loans disclosed by Chinese listed companies, we analyze the underlying channels through which aggressive tax planning facilitates the diversion of corporate resources by firm insiders. Using path analysis, we document that the path from tax aggressiveness to related loans is mediated by both the additional cash flows from tax savings and the increased financial opacity from tax planning, and that additional cash flows plays a much more important role than opacity at helping controlling shareholders to divert corporate resources under the guise of tax aggressiveness. Beyond the two mediated paths, we also detect a residual, direct path from tax aggressiveness to related loans. After an exogenous shock from the government crackdown on diversionary related loans, we find the direct path is fully mediated by the two indirect paths, suggesting that tunneling via related loans only occurs at firms where insiders can mask tunneling under the cover of opacity or can justify related loans on grounds of abnormal cash flows from tax savings. Our evidence supports the notion that greater outside scrutiny increases the hurdle for, but does not entirely eradicate, diversion facilitated by tax aggressiveness. Collectively, our research lends some support to recent theory on the importance of taxes to corporate governance by demonstrating how the agency costs of tax planning allow certain shareholders to benefit from firm activities at the expense of others.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264068872
Category :
Languages : en
Pages : 112
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Book Description
High Net Worth Individuals (HNWIs) pose significant challenges to tax administrations due to the complexity of their affairs, their revenue contribution, the opportunity for aggressive tax planning, and the impact of their compliance behaviour on ...
