The Resource Canadian MNCs international tax planning : theory and practice

Canadian MNCs international tax planning : theory and practice

Label
Canadian MNCs international tax planning : theory and practice
Title
Canadian MNCs international tax planning : theory and practice
Creator
Subject
Language
eng
Summary
This article analyses the role of international tax planning in Canadian multinational companies' (MNCs) outbound investment decisions in theory and practice. The authors identify the framework of international tax planning. They can show that international tax planning is an important factor (value driver) to influence the value of the whole firm (Canadian-based MNC group) and not only of a single investment project. They also introduce a new developed tax structure (tax engineering) for Canadian MNCs to apply international tax planning. According to this new tax management approach, the value of the whole group can be enhanced if each major investment project is wrapped in a specific developed and fine-tuned international tax structure. Establishing tax-optimized cross-border investment structures may enhance Canadian MNCs' global competitive position considerably. Moreover, the Canadian CFC exemption for foreign financing affiliates (section 95(2)(a) ITA) is critically evaluated in light of tax policy, international competitiveness and global tax competition as well as the current comments of the OECD on international tax planning in its reports on base erosion and profit shifting (2013) and hybrid mismatch arrangements (2012)
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 42 (2014),
http://library.link/vocab/creatorName
  • Kollruss, T
  • Weißert, S
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • tax planning
  • MNE
  • CFC
  • tax structure
Label
Canadian MNCs international tax planning : theory and practice
Instantiates
Publication
Label
Canadian MNCs international tax planning : theory and practice
Publication

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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