The Resource What is substantial economic activity for tax purposes in the context of the European Union and the OECD initiatives against harmful tax competition?

What is substantial economic activity for tax purposes in the context of the European Union and the OECD initiatives against harmful tax competition?

Label
What is substantial economic activity for tax purposes in the context of the European Union and the OECD initiatives against harmful tax competition?
Title
What is substantial economic activity for tax purposes in the context of the European Union and the OECD initiatives against harmful tax competition?
Creator
Subject
Language
eng
Summary
This article deals with the substantial economic activity criterion as defined in the Code of Conduct for Business Taxation, in the OECD Report Harmful Tax Competition - An Emerging Global Issue and, more recently, in item 5 of the base erosion and profit shifting (BEPS) Action Plan, namely regarding, at this phase, its application to patent box tax regimes. The author analyses the juridical and political controversy on the various approaches to determine what substantial economic activity actually means, specifically the value added approach, the transfer pricing approach and the nexus approach, this last criterion being the one preferred by the majority of the Member States of the OECD and the European Union. Finally the author raises some questions about the application of the recent agreement between UK and Germany concerning the British patent box regime. Is it compatible with the EU law, especially with the EU State Aid rules?
Citation source
In: EC tax review. - Alphen aan den Rijn. - Vol. 24 (2015),
http://library.link/vocab/creatorName
Santos, A.C. dos
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • Code of Conduct
  • harmful tax competition
  • patent box
  • economic activity
  • State aid
  • substance over form
  • transfer pricing
  • nexus approach
  • BEPS Project (OECD)
Label
What is substantial economic activity for tax purposes in the context of the European Union and the OECD initiatives against harmful tax competition?
Instantiates
Publication
Label
What is substantial economic activity for tax purposes in the context of the European Union and the OECD initiatives against harmful tax competition?
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...