Corporate loss utilisation through aggressive tax planning
Contributors: OECD iLibrary
Publisher: OECD
Published: 2011
Place of publication: Paris
Language: eng
Number of pages: 88
ISBN-13: 9789264119215; 9789264119222
Subjects: Corporations; Taxation; Tax planning
Description: Corporate losses raise compliance risks if aggressive tax planning is used as a means of increasing or accelerating tax relief in ways not intended by the legislator, or to generate artificial losses. This report describes the size of loss carry-forwards, the rules applicable in relation to losses, and identifies the following risk areas: corporate reorganisations, financial instruments and non-arm’s length transfer pricing. After having summarised aggressive tax planning schemes on losses, as well as country detection and response strategies, it offers a number of conclusions and recommendation for tax administration and tax policy officials.
Notes: "This work is published on the responsibility of the Secretary-General of the OECD"--T.p. verso.

"Corrigenda to OECD publications may be found online at: www.oecd.org/publishing/corrigenda"--T.p. verso.

OECD code: 23 2011 47 1 P.

Includes bibliographical references.

Also available to subscribers online.
Table of contents: title: Foreword; title: Abbreviations; title: Executive Summary; title: Introduction; title: Size of Corporate Tax Losses; title: Policy Issues in the Tax Treatment of Losses; title: Country Rules on Corporate Tax Losses; title: Schemes Involving Tax Losses; title: Strategies for Detecting Schemes Involving Tax Losses; title: Strategies for Responding to Schemes Involving Tax Losses; title: Conclusions and Recommendations; title: References; title: Annex A; title: Size of loss carry-forwards compared to loss carry-forwards in percentage of gross domestic product.