Limiting Base Erosion
Author: Erik Pinetz
Publisher:
Published: 2017
Total Pages: 548
ISBN-13: 9783707337587
DOWNLOAD EBOOK →Author: Erik Pinetz
Publisher:
Published: 2017
Total Pages: 548
ISBN-13: 9783707337587
DOWNLOAD EBOOK →Author: OECD
Publisher: OECD Publishing
Published: 2015-10-05
Total Pages: 120
ISBN-13: 9264241175
DOWNLOAD EBOOK →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 4.
Author: Erik Pinetz
Publisher: Linde Verlag GmbH
Published: 2017-08-30
Total Pages: 550
ISBN-13: 3709408814
DOWNLOAD EBOOK →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”.
Author: OECD
Publisher: OECD Publishing
Published: 2016-12-22
Total Pages: 212
ISBN-13: 9264268332
DOWNLOAD EBOOK →The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, based on taxable EBITDA. Further work on two aspects of the common approach was completed in 2016 and this is included in this update.
Author: Oecd
Publisher: Org. for Economic Cooperation & Development
Published: 2015-10-15
Total Pages: 118
ISBN-13: 9789264241169
DOWNLOAD EBOOK →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 4.
Author: Organization for Economic Cooperation and Development
Publisher: Organization for Economic Co-Operation & Development
Published: 2016-12-15
Total Pages: 0
ISBN-13: 9789264268326
DOWNLOAD EBOOK →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).
Author: OECD
Publisher: OECD Publishing
Published: 2016-07-18
Total Pages: 63
ISBN-13: 9264261591
DOWNLOAD EBOOK →Author: T. Adam
Publisher:
Published: 2017
Total Pages:
ISBN-13:
DOWNLOAD EBOOK →In October 2015, the OECD/G20 Base Erosion and Profit Shifting (BEPS) project issued its final report on Action 4, limiting tax base erosion via interest deductions and other financial payments. The UK government responded immediately with a public consultation on the implementation of the OECD's recommended approach and this was followed by a further consultation that closed in August 2016.
Author: Gianluigi Bizioli
Publisher: Kluwer Law International B.V.
Published: 2020-02-07
Total Pages: 386
ISBN-13: 9403512318
DOWNLOAD EBOOK →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.
Author: OECD
Publisher: OECD Publishing
Published: 1998-05-19
Total Pages: 82
ISBN-13: 9264162941
DOWNLOAD EBOOK →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.