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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Size of Corporate Tax Losses
This chapter presents data on the size of corporate loss carry-forwards in 11 of the 17 countries that participated in this study. It discusses the potential impact on future government revenues.
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