Action Plan on Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264202714
Total Pages : 44 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis Action Plan on Base Erosion and Profit Shifting by : OECD

Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Addressing Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264192743
Total Pages : 91 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Addressing Base Erosion and Profit Shifting by : OECD

Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Global Challenges in Public Finance and International Relations

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Author :
Publisher : IGI Global
ISBN 13 : 1522575650
Total Pages : 304 pages
Book Rating : 4.5/5 (225 download)

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Book Synopsis Global Challenges in Public Finance and International Relations by : ?ahin Duran, Deniz

Download or read book Global Challenges in Public Finance and International Relations written by ?ahin Duran, Deniz and published by IGI Global. This book was released on 2019-03-29 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although the concept of international public goods has been established, new international public needs arise by the day. For example, while there are many taxation problems and debates that have not yet been resolved internationally, many new tax-related problems like international transfer pricing, taxation of virtual profits, and taxation of electronic commerce are being added. These issues require studies that will discuss a new agenda and propose solutions for these dilemmas and problems. Global Challenges in Public Finance and International Relations provides an innovative and systematic examination of the present international financial events and institutions, international financial relations, and fiscal difficulties and dilemmas in order to discuss solutions for potential problems in the postmodern world. Highlighting topics such as international aid, public debt, and corporate governance, this publication is designed for executives, academicians, researchers, and students of public finance.

OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264263438
Total Pages : 24 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2016-08-26 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.

Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report

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Author :
Publisher : OCDE
ISBN 13 : 9789264241183
Total Pages : 80 pages
Book Rating : 4.2/5 (411 download)

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Book Synopsis Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report by : OCDE,

Download or read book Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015-10-12 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241159
Total Pages : 75 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 3.

OECD/G20 Base Erosion and Profit Shifting Project Mandatory Disclosure Rules, Action 12 - 2015 Final Report

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Author :
Publisher : Org. for Economic Cooperation & Development
ISBN 13 : 9789264241374
Total Pages : 100 pages
Book Rating : 4.2/5 (413 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Mandatory Disclosure Rules, Action 12 - 2015 Final Report by : Oecd

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Mandatory Disclosure Rules, Action 12 - 2015 Final Report written by Oecd and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-20 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 12.

Harmful Tax Competition An Emerging Global Issue

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264162941
Total Pages : 82 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Harmful Tax Competition An Emerging Global Issue by : OECD

Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

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Author :
Publisher : Org. for Economic Cooperation & Development
ISBN 13 : 9789264241237
Total Pages : 186 pages
Book Rating : 4.2/5 (412 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-19 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241132
Total Pages : 458 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 2.

OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241175
Total Pages : 120 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 120 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Double Non-taxation and the Use of Hybrid Entities

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041199926
Total Pages : 411 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Double Non-taxation and the Use of Hybrid Entities by : Leopoldo Parada

Download or read book Double Non-taxation and the Use of Hybrid Entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2018-04-18 with total page 411 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired a particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth critique of the BEPS Action Plan 2 with regard to hybrid entities, this timely book provides a critical review of the OECD’s approach and proposes a deeply informed alternative method based on the tax policy aims of simplicity, coherence and ease of administration. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasizing the international tax context, including the application of tax treaties. Among the seminal matters covered are the following: – foundations of the concepts of double non-taxation and hybrid entities, absent of the specific limitations of domestic tax legislation; – extensive analysis based on the rules of characterization of foreign entities for tax purposes in the United States, Spain, Denmark and Germany, as well as on the Poland/United States and Canada/United States tax treaties; – detailed analysis on the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument, especially having in mind the position of developing (source) countries; and – EU tax law as part of the international context, including an extensive analysis on the EU Anti-Tax Avoidance Directive (ATAD) I and ATAD II. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding double non-taxation and hybrid entities, this analysis elaborates solutions applicable to a generality of cases worldwide, and thus hugely promotes the urgent quest for alternative solutions.

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report

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Author :
Publisher : OCDE
ISBN 13 : 9789264241466
Total Pages : 70 pages
Book Rating : 4.2/5 (414 download)

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Book Synopsis Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report by : OCDE,

Download or read book Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports

Tax Challenges Arising from Digitalisation – Interim Report 2018

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Author :
Publisher : OECD
ISBN 13 : 9264301763
Total Pages : 260 pages
Book Rating : 4.2/5 (643 download)

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Book Synopsis Tax Challenges Arising from Digitalisation – Interim Report 2018 by : Collectif

Download or read book Tax Challenges Arising from Digitalisation – Interim Report 2018 written by Collectif and published by OECD. This book was released on 2018-05-29 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.

Neutralising the Effects of Hybrid Mismatch Arrangements

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Author :
Publisher : OCDE
ISBN 13 : 9789264218796
Total Pages : 99 pages
Book Rating : 4.2/5 (187 download)

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Book Synopsis Neutralising the Effects of Hybrid Mismatch Arrangements by : Oecd

Download or read book Neutralising the Effects of Hybrid Mismatch Arrangements written by Oecd and published by OCDE. This book was released on 2014-09-16 with total page 99 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.

Preventing the Artificial Avoidance of Permanent Establishment Status

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Author :
Publisher : OCDE
ISBN 13 : 9789264241213
Total Pages : 48 pages
Book Rating : 4.2/5 (412 download)

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Book Synopsis Preventing the Artificial Avoidance of Permanent Establishment Status by : OCDE,

Download or read book Preventing the Artificial Avoidance of Permanent Establishment Status written by OCDE, and published by OCDE. This book was released on 2015-10-22 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.

Action Plan on Base Erosion and Profit Shifting

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Author :
Publisher :
ISBN 13 :
Total Pages : 40 pages
Book Rating : 4.:/5 (129 download)

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Book Synopsis Action Plan on Base Erosion and Profit Shifting by : Organizacion de Cooperación y Desarrollo Economico

Download or read book Action Plan on Base Erosion and Profit Shifting written by Organizacion de Cooperación y Desarrollo Economico and published by . This book was released on 2013 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: