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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 Responding to Schemes Involving Tax Losses

This chapter presents response strategies to aggressive tax planning schemes. It looks at strategies that deny or limit the tax benefits of aggressive tax planning schemes, other strategies that influence taxpayer behaviour, and strategies that target promoters and other intermediaries.

English

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