The Resource Tax sparing : good intentions, unintended results

Tax sparing : good intentions, unintended results

Label
Tax sparing : good intentions, unintended results
Title
Tax sparing : good intentions, unintended results
Creator
Subject
Language
eng
Summary
Canada, like most other OECD member nations, has negotiated tax-sparing provisions with tax treaty partners. Over the years, the OECD has generally supported tax-sparing provisions as a means of ensuring that tax incentives offered by developing countries are not eroded through the tax treatment of the income from the advantaged activities by the investor?s country of residence. In 1998, the OECD reconsidered its position and expressed concern about abuses associated with tax sparing. The first part of this article looks at the debate over tax sparing and its history in the United States, at the OECD, and in Canada. The article examines the OECD?s current concern with tax sparing and some of the reasons why developing countries might consider it an important economic development tool. The second part of the article focuses on tax-sparing tax-avoidance transactions and considers whether, and on what basis, such transactions might be challenged by the Canada Customs and Revenue Agency in the context of the Canada-Brazil income tax convention (1984). This treaty is of particular interest because, among Canadian tax treaties currently in force, it contains the most generous tax-sparing provisions
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 49 (2001),
http://library.link/vocab/creatorName
Toaze, D
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax sparing credit
  • tax treaty
  • tax incentive
  • investment incentive
Label
Tax sparing : good intentions, unintended results
Instantiates
Publication
Label
Tax sparing : good intentions, unintended results
Publication

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