Limiting Base Erosion

Author: Erik Pinetz
Publisher: Linde Verlag GmbH
ISBN: 3709408822
Size: 12.87 MB
Format: PDF, Kindle
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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 ...

Limiting Base Erosion Involving Interest Deductions And Other Financial Payments Action 4 2016 Update

Author: Organization for Economic Cooperation and Development
Publisher: Organization for Economic Co-Operation & Development
ISBN: 9789264268326
Size: 56.14 MB
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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).

Oecd G20 Base Erosion And Profit Shifting Project Preventing The Granting Of Treaty Benefits In Inappropriate Circumstances

Author: OECD
Publisher: OECD Publishing
ISBN: 9264219129
Size: 24.63 MB
Format: PDF, ePub
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These doctrines and principles of interpretation, which vary from country to
country and evolve over time based on refinements or changes resulting from
subsequent court decisions, are essentially views expressed by courts as to how
tax legislation should be interpreted. Whilst the ... In some limited cases, however
, it has been argued that some provisions that are aimed at the taxation of non-
residents could be interpreted as limiting a Contracting State's right to tax its own

Oecd G20 Base Erosion And Profit Shifting Project Countering Harmful Tax Practices More Effectively Taking Into Account Transparency And Substance

Author: OECD
Publisher: OECD Publishing
ISBN: 9264218971
Size: 12.14 MB
Format: PDF
View: 2668
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Under these front-end regimes, the expenditures and benefits are directly linked
because the expenditures are used to calculate the tax benefit. The nexus
approach extends this principle to apply to “back-end” tax regimes that apply to
the income earned after the creation and exploitation of the IP. Thus, rather than
limiting jurisdictions to IP regimes that only provide benefits directly to the
expenditures incurred to create the IP, the nexus approach also permits
jurisdictions to provide ...

The Liquidation Of Government Debt

Author: Ms. Carmen Reinhart
Publisher: International Monetary Fund
ISBN: 1498338380
Size: 13.31 MB
Format: PDF, ePub, Docs
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Through extensive documentation of the regulations covering the financial and
external sectors we also trace out the evolution of “captive domestic audiences”
where these debts are placed, which are an integral part of limiting tax base
erosion. Finding highyield alternatives (to government debt) saving vehicles in
the era of financial repression was no easy task. Capital controls kept many
potential high yield investment possibilities off limits while available domestic
alternatives ...

Tax Notes International

Size: 38.29 MB
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If a case were brought before a tax court, the judge would have to rule based on
existing tax laws and regulations, without considering the interpretations
provided in the tax authorities' publication. considering introducing thin If Mexican
tax ... If Mexican tax authorities are seriously considering introducing thin
capitalization rules, tax reform will be required, since there currently is no legal
basis for limiting the deductibility of interest expense for companies that may be
too thinly ...

The Journal Of Geology

Author: Thomas Chrowder Chamberlin
Size: 13.67 MB
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JOSEPH E. POGUE U.S. National Museum, Washington Mr. C. R. Keyes, in a
recent article in the Journal of Geology,1 discusses the well-known fact that in
arid regions erosion proceeds independently of sea-level and often is effective
even below it. He sets a limit, however, to the ... situ in the base of the lacustrine
deposits, concludes that the lake was contemporaneous with man. In regard to its
origin, ...

Erosion Of The Property Tax Base

Author: Nancy Y. Augustine
Publisher: Lincoln Inst of Land Policy
ISBN: 9781558441866
Size: 22.21 MB
Format: PDF, Docs
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The chapters in this book provide analyses of recent property tax trends; examine several responses to the increasing importance of residential property; estimate the extent of property tax base erosion and its effects; and consider other ...