Tax Sparing

Tax Sparing

A Reconsideration You do not have access to this content

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24 Feb 1998
9789264162433 (PDF) ;9789264160224(print)

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Tax sparing provisions have now more than four decades of history in bilateral tax treaties, including treaties between OECD countries. But the world of today is quite different from that when the positions of OECD Member and non-member countries towards tax sparing were developed. These changes in the international setting have led countries to reconsider their attitude towards tax sparing and the design of such provisions. This report examines the practices of Member countries and explains why Member countries have become more reluctant to grant tax sparing in treaties. It also provides a number of suggested "best practices" on the design of tax sparing provisions in tax treaties.

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Table of Contents

I. Introduction
II. The Historical Development of Tax Sparing Provisions
III. Traditional Country Provisions on the Issue of Tax Sparing
IV. Tax Sparing: An Emerging Consensus on the Need for a Re-Evaluation
V. Recent Trends in Tax Sparing Provisions
VI. Best Practices in Designing Tax Sparing Provisions
VII. Recommendations
Annex I. Member Country Tax Sparing Provisions Referred to in the Report
Annex II. Tax Sparing Provisions in Treaties between OECD Member Countries
Annex III. Tax Sparing Provisions in Treaties between OECD Member and Certain Non-Member Countries
Annex IV. Tax Avoidance Scheme I
Annex V. Tax Avoidance Scheme II
Annex VI. Anti-Abuse Provisions
Annex VII. Article 23B of the Commentary to the OECD Model Tax Convention
Annex VIII. Recommendation of the Council on the Granting and Design of Tax Sparing in Tax Conventions

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