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Taxing Multinationals

Taxing Multinationals

Preventing tax base erosion through the reform of cross-border intercompany deductions, ATTA Doctoral Series, vol. 7

by Ann Kayis-Kumar
Paperback
Publication Date: 15/05/2020

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The rise of multinationals and their ability to engage in sophisticated cross-border tax planning have governments and policymakers struggling to deal with the implications. Currently, governments commonly utilise corporate interest limitation rules since they are widely perceived as an anti-avoidance mechanism that limits tax base erosion. Despite this perception, the legal basis for these rules does not reconcile with the economic basis because they present only imperfect solutions to the problem of the 'debt bias'.Taxing Multinationals considers whether equalising the tax deductibility of fungible intercompany funding activities would minimise opportunities for cross-border tax planning by multinationals. It approaches the issue of thin capitalisation by conceptualising the cross-border debt bias as the 'disease' and thin capitalisation as merely the 'symptom'. It then explores whether the 'disease' would be better addressed by retaining interest limitation rules in their current form or if an alternative reform would be more effective.
ISBN:
9780190319311
9780190319311
Category:
Taxation
Format:
Paperback
Publication Date:
15-05-2020
Publisher:
Oxford University Press Australia
Country of origin:
Australia
Pages:
260
Dimensions (mm):
240x160x18mm
Weight:
0.54kg

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