The Resource Base erosion and profit shifting

Base erosion and profit shifting

Base erosion and profit shifting
Base erosion and profit shifting
QUESTIONS: By reference to local legal or regulatory provisions, administrative practices, results of tax audits or case law, please comment on the likelihood of, and scope for local challenges, and possible legal defences, in respect of: - prolonged losses; - low margins; - "wrongly characterised" arrangements; - uncommercial arrangements that should be disregarded. Referring to: 1. local options for reducing the risk of such challenges (e.g. real time working, APAs, securing low risk status, having robust agreements and transfer pricing analyses in place); 2. what specific legal restrictions are in place to limit TP planning involving IP, risk transfer, high value function transfer or cross-border financing; 3. any General Anti-Avoidance Rule restrictions on transfer pricing planning; 4. and - if possible - whether the answers are different for internet-based businesses
Citation source
In: Transfer pricing forum. - Arlington. - Vol. 4 (2013), no. 1 (May) ; 112 p
Geographic coverage
Language note
  • BEPS
  • losses
  • transfer pricing
  • APA
  • risk
  • financing
  • GAAR
  • intellectual property
  • intangibles
  • reorganization
  • tax treaty
Base erosion and profit shifting

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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