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Corporate Loss Utilisation through Aggressive Tax Planning

image of 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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Strategies for Detecting Schemes Involving Tax Losses

This chapter examines strategies employed to detect aggressive tax planning schemes involving tax losses. It offers a general overview of detection strategies and looks at those employed by the 17 countries that participated in this study.

English

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