Corporate loss utilisation through aggressive tax planning

Resource Information

The work Corporate loss utilisation through aggressive tax planning represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Corporate loss utilisation through aggressive tax planning

Subject

• loss relief
• aggressive tax planning
• losses

Language

eng

Summary

This report deals with corporate tax losses. The term "losses" has to be understood broadly for purposes of this report: although the report deals primarily with the tax treatment of taxpayers which have suffered overall losses, it also examines issues relevant to deductions which may reduce a taxpayer's profits without necessarily resulting in an overall loss. The report deals with both real and artificial losses, the latter constituting an even greater source of concern for revenue bodies. For the purposes of this report, schemes on real losses are those where the taxpayer seeks to use losses which have been economically incurred somewhere, by the same taxpayer or by a different one, in ways not intended or contrary to the principles underlying the relevant rules. On the other hand, artificial losses are those arising from schemes that seek to generate losses for tax purposes with no economic loss arising anywhere, whether at the level of the taxpayer claiming loss relief or somewhere else. The report also addresses the issue of multiple deductions of the same (real or artificial) loss, typically through hybrid mismatch arrangements

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction