The Resource Aggressive tax planning : an analysis from an EU perspective

Aggressive tax planning : an analysis from an EU perspective

Label
Aggressive tax planning : an analysis from an EU perspective
Title
Aggressive tax planning : an analysis from an EU perspective
Creator
Subject
Language
eng
Summary
Courts in many countries have found that the tax laws should be interpreted so as to prevent their avoidance by the use of transactions that have no business purpose. This goes to say that the lack of a proper business motive or transactions which do not reflect the economic reality may be interpreted as a step further to tax avoidance and therefore leads to aggressive tax planning (ATP). The European Commission (EC) launched a public consultation on 10 November 2016 to gather feedback on the way forward for EU action on advisers and intermediaries who facilitate tax evasion, tax avoidance and aggressive tax planning. Following the EC's public consultation, the EC published a tax paper entitled the Study on Structures of Aggressive Tax Planning and Indicators, highlighting the model ATP structures and identifying ATP indicators which facilitate or allow ATP. This article examines the said tax paper by selecting the most prevalent ATP structures and how these are countered though the EC's Anti-Tax Avoidance Package
Citation source
In: EC tax review. - Alphen aan den Rijn. - Vol. 26 (2017), no. 5 ; p. 257-273
http://library.link/vocab/creatorName
Cachia, F
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • aggressive tax planning
  • tax evasion
  • tax avoidance
  • tax haven
  • offshore company
  • hybrid financial instrument
  • hybrid entity
  • patent box
  • exemption
  • beneficial ownership
  • dividend withholding tax
  • deductions
  • thin capitalization
  • notional interest deduction
  • royalties
  • CFC
Label
Aggressive tax planning : an analysis from an EU perspective
Instantiates
Publication
Label
Aggressive tax planning : an analysis from an EU perspective
Publication

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