The Resource Base erosion by intra-group debt and BEPS Project Action 4's best practice approach - a case study of Chevron

Base erosion by intra-group debt and BEPS Project Action 4's best practice approach - a case study of Chevron

Label
Base erosion by intra-group debt and BEPS Project Action 4's best practice approach - a case study of Chevron
Title
Base erosion by intra-group debt and BEPS Project Action 4's best practice approach - a case study of Chevron
Creator
Subject
Language
  • eng
  • eng
Summary
It is well known that many multinational enterprises use intra-group debts for tax avoidance purposes. Action 4 of the OECD's Base Erosion and Profit Shifting (BEPS) project represents a recent major contribution to the literature on the subject, providing important insights into the design features and issues of different forms of interest limitation regimes in practice. At the other side of the world, a recent major tax case and the Senate enquiry into corporate tax avoidance in Australia revealed detailed information about how Chevron used intra-group debts in its tax structures, which is very difficult, if not impossible, to discern from its financial statement. It provides a timely case study of how intra-group debts are used in practice, setting the stage for an evaluation of Action 4's recommendations. This article first analyses two tax structures used by Chevron in Australia as a case study to highlight the key issues arising from intra-group debts. Secondly, using empirical data on Chevron, this article evaluates whether Action 4's recommendations are effective for addressing BEPS arising from intra-group debt
Citation source
In: British tax review. - London. - (2017), no. 1 ; p. 80-108
http://library.link/vocab/creatorName
Ting, A
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • BEPS Project (OECD)
  • intra-group financing
  • debt
  • interest deduction
  • tax structure
  • tax avoidance
  • international tax planning
  • thin capitalization
  • transfer pricing
Label
Base erosion by intra-group debt and BEPS Project Action 4's best practice approach - a case study of Chevron
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2017/A-D/BTR/1_80-108.pdf
Publication
Note
20170412

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