Corporate Loss Utilisation through Aggressive Tax Planning
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.
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Policy Issues in the Tax Treatment of Losses
This chapter presents the different policy considerations related to the use of losses for tax purposes. It looks, in general terms, at the tax policy reasons behind various legislative choices.
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