The Resource Transfer pricing of financial transactions, stuck between a rock and a hard place

Transfer pricing of financial transactions, stuck between a rock and a hard place

Label
Transfer pricing of financial transactions, stuck between a rock and a hard place
Title
Transfer pricing of financial transactions, stuck between a rock and a hard place
Creator
Subject
Language
eng
Summary
The EU earnings stripping rules are expected to come into force by 1 January 2019, and multinationals will be faced with a fixed ratio rule that determines to what extent borrowing costs are deductible for tax purposes. Similar rules have already been introduced in the U.S. Also, as a result of the OECD Final Report on BEPS Action 4, more countries are expected to follow. The authors explore the impact of these new earnings stripping rules on taxpayers, and discuss the interplay of relevant developments with the transfer pricing aspects of financial transactions
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 27 (2018), no. 12 ; 4 p
http://library.link/vocab/creatorName
  • Breggen, M.E.P. van der
  • Moerer, O
  • Montero C., O
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • earnings stripping
  • BEPS Action Plan
  • interest deduction
  • fixed ratio rule
  • group ratio rule
  • transfer pricing
  • intercompany transaction
  • arm's length principle
Label
Transfer pricing of financial transactions, stuck between a rock and a hard place
Instantiates
Publication
Label
Transfer pricing of financial transactions, stuck between a rock and a hard place
Publication

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