The Resource Interest limitation rules in the post-BEPS era

Interest limitation rules in the post-BEPS era

Label
Interest limitation rules in the post-BEPS era
Title
Interest limitation rules in the post-BEPS era
Creator
Subject
Language
eng
Summary
The focus in the OECD base erosion and profit shifting (BEPS) project and the Anti-Tax Avoidance Directive (ATAD) is to counteract the use of debt in international tax planning strategies to ensure taxation where the value is created (economic activity). This article focuses on one anti-tax avoidance measure: interest limitation rules as addressed in BEPS action 4 and in ATAD Article 4. This article addresses the need for interest limitation rules, analyses the recommended approach in BEPS action 4 and the minimum interest deduction limitation rule in the EU according to Article 4 in ATAD, and the implications of OECD action 4 and ATAD Article 4. Lastly, the article discusses alternatives to these interest deduction limitation rules as a way to address BEPS
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 45 (2017), no. 11 ; p. 750-763
http://library.link/vocab/creatorName
Tell, M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • ATAD
  • interest deduction
  • economic activity
  • anti-avoidance
Label
Interest limitation rules in the post-BEPS era
Instantiates
Publication
Label
Interest limitation rules in the post-BEPS era
Publication

Library Locations

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