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Business Corporate Loss Utilisation through Aggressive Tax Planning

Posted on 2011-08-08




Name:Business Corporate Loss Utilisation through Aggressive Tax Planning
ASIN/ISBN:9789264119215
Publish Date:9789264119215 9789264119222
Pages:93 pages
File size:1 Mb
Publish Date: Aug 2011
Pages: 93 pages
File Type: PDF
File Size: 1 MB
Other Info: OECD; ISBN: 9789264119215 9789264119222
   Business Corporate Loss Utilisation through Aggressive Tax Planning

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Corporate Loss Utilisation through Aggressive Tax Planning

The report summarises aggressive tax planning schemes encountered by revenue bodies in participating countries, together with their detection and response strategies. These schemes aim for instance at shifting profits or losses to related or unrelated parties, circumventing restrictions on the use of losses, creating artificial losses and obtaining the dual/multiple deduction of the same loss. The report ends with certain conclusions and reccomendations for revenue bodies and government officials.

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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.

Table of Contents

Foreword

Abbreviations

Executive Summary

Introduction

Chapter 1 Size of Corporate Tax Losses

Chapter 2 Policy Issues in the Tax Treatment of Losses

Chapter 3 Country Rules on Corporate Tax Losses

Chapter 4 Schemes Involving Tax Losses

Chapter 5 Strategies for Detecting Schemes Involving Tax Losses

Chapter 6 Strategies for Responding to Schemes Involving Tax Losses

Conclusions and Recommendations

References

Annex A

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