Limiting Base Erosion

Author: Erik Pinetz
Publisher: Linde Verlag GmbH
ISBN: 3709408814
Size: 44.68 MB
Format: PDF, ePub
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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: 79.73 MB
Format: PDF, ePub, Mobi
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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: 66.48 MB
Format: PDF, ePub, Mobi
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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 residents. Such interpretations have been
rejected in paragraph 6.1 of the Commentary on Article 1, which deals with a
Contracting State's right to tax partners who are its own residents on their share
of the income of a partnership that is treated as a resident of the other Contracting
State, as well ...

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: 17.32 MB
Format: PDF
View: 999
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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: 48.50 MB
Format: PDF, ePub, Mobi
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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 ...

Transparenz Und Informationsaustausch

Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709409004
Size: 65.84 MB
Format: PDF, Mobi
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Von verstärkter Transparenz bis zum gläsernen Steuerpflichtigen Wie geheim sollen Steuerdaten sein? Was ist durch das Verrechnungspreisdokumentationsgesetz zu beachten? Welche Auswirkungen hat die vermehrte Transparenz im Steuerrecht?

Tax Notes International

Size: 31.32 MB
Format: PDF, Docs
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On October 15, 1996, the Second Chamber of the Dutch Parliament approved a
revised version of a bill intended to encourage investment in the Netherlands,
while limiting the use of tax-base erosion techniques by corporations. Although
the bill's main provisions have not changed fundamentally from those that were
introduced earlier this year, the final bill reflects several important amendments
and clarifications, including those regarding Dutch and foreign finance
companies, and ...