publication . Article . 2013

Interest Deductibility and the BEPS Action Plan: nihil novi sub sole?

Traversa, Edoardo;
Open Access English
  • Published: 01 Jan 2013
  • Publisher: Sweet & Maxwell Ltd.
  • Country: Belgium
Abstract
Interest payments between affiliated companies which aim at shifting profit from high to low tax countries are a well-known and frequently used tool in international tax planning. It is therefore not surprising that in the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) (Action Plan) considerable attention is given to the measures limiting the deductibility of (excessive) intra-group interest payments.1 The Action Plan does not, however, provide any clear guidance as to which, among the domestic anti-abuse measures existing in OECD or non-OECD member countries, should be recommended. Moreover, the OECD, by sticking to the arm’s length standard, refus...
Subjects
free text keywords: International taxation, Corporate taxation, Interest deductibility
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