Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report PDF Download
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Author: OCDE,
Publisher: OCDE
ISBN: 9789264241183
Category : Corporations
Languages : en
Pages : 80
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Book Description
Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached on the nexus approach which uses expenditures as a proxy for substantial activity and ensures that taxpayers can only benefit from IP regimes where they engaged in research and development and incurred actual expenditures on such activities. The same principle can also be applied to other preferential regimes so that such regimes are found to require substantial activity where the taxpayer undertook the core income generating activities. In the area of transparency, a framework has been agreed for the compulsory spontaneous exchange of information on rulings that could give rise to BEPS concerns in the absence of such exchange. The results of the application of the existing factors applied by the FHTP, and the elaborated substantial activity and transparency factors, to a number of preferential regimes are included in this report.
Author: OCDE,
Publisher: OCDE
ISBN: 9789264241183
Category : Corporations
Languages : en
Pages : 80
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Book Description
Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached on the nexus approach which uses expenditures as a proxy for substantial activity and ensures that taxpayers can only benefit from IP regimes where they engaged in research and development and incurred actual expenditures on such activities. The same principle can also be applied to other preferential regimes so that such regimes are found to require substantial activity where the taxpayer undertook the core income generating activities. In the area of transparency, a framework has been agreed for the compulsory spontaneous exchange of information on rulings that could give rise to BEPS concerns in the absence of such exchange. The results of the application of the existing factors applied by the FHTP, and the elaborated substantial activity and transparency factors, to a number of preferential regimes are included in this report.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264241191
Category :
Languages : en
Pages : 82
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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 5.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264162941
Category :
Languages : en
Pages : 82
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Book Description
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264218971
Category :
Languages : en
Pages : 68
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Book Description
This report on preferential tax regimes sets out the progress made to date in the context of the OECD/G20 Base Erosion and Profit Shifting Project.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264237860
Category :
Languages : zh-CN
Pages : 48
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Book Description
Author: Ina Kerschner
Publisher: Linde Verlag GmbH
ISBN: 3709409047
Category : Law
Languages : en
Pages : 488
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Book Description
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Author: Kyriazis
Publisher: Oxford University Press
ISBN: 019887829X
Category : Law
Languages : en
Pages : 289
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Book Description
The intersection between fiscal state aid and taxation has become more topical than ever. Mounting financial crises have left EU Member States scrambling to increase their tax revenue, balance their budgets, and attract capital. Taking advantage of these trends, multinational enterprises have lobbied for favourable tax arrangements, raising questions about the breadth of control the Commission can and should practise. To address egregious instances of favourable taxation, the Commission has tried to simultaneously use soft law and deploy Treaty rules on state aid. Fiscal State Aid Law and Harmful Tax Competition in the EU examines the use of state aid rules against national tax measures. Kyriazis's book presents a targeted investigation of these measures in two parts. The first part addresses Commission decisions and ECJ judgments of the early 2000s, which the author calls the "first wave". The second part consists of all the recent Commission decisions and investigations into tax schemes and individual tax rulings, most notably the Apple, Fiat, Starbucks, and Amazon investigations, which Kyriazis labels the "second wave". The characteristics and common threads of each wave are set out, their similarities and differences dissected, and their nexus to the EU's fight against harmful tax competition explored. Containing a thorough analysis of the legal concept of fiscal state aid under Article 107(1) of the Treaty on the Functioning of the European Union, this book will be of interest to scholars of European and International Tax law and practitioners working in the field of European competition law.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264033998
Category :
Languages : en
Pages : 14
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Book Description
This Report describes progress made in identifying and addressing harmful tax practices within and outside the OECD. In addition to reporting on the work done in connection with tax havens, it also discusses the work related to Member countries and ...
Author: OECD
Publisher: OECD Publishing
ISBN: 9264283951
Category :
Languages : en
Pages : 48
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Book Description
This progress report is an update to the 2015 BEPS Action 5 report and contains the results of the review of all Inclusive Framework members' preferential tax regimes that have been identified.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264538054
Category :
Languages : en
Pages : 462
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Book Description
BEPS Action 5 is one of the four minimum standards which all members of the OECD/G20 Inclusive Framework on BEPS have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which, in the absence of transparency, could give rise to BEPS concerns.
