Aggressive tax planning
Corporate Loss Utilisation through Aggressive Tax Planning
Corporate losses raise compliance risks if aggressive tax planning is used as a means
of increasing or accelerating tax relief in ways not intended by the legislator, or
to generate artificial losses. This report describes the size of loss carry-forwards,
the rules applicable in relation to losses, and identifies the following risk areas:
corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
After having summarised aggressive tax planning schemes on losses, as well as country
detection and response strategies, it offers a number of conclusions and recommendation
for tax administration and tax policy officials.
Published on August 03, 2011
TABLE OF CONTENTS
| Foreword | |
| Abbreviations | |
| Executive Summary | |
| Introduction | |
| Size of Corporate Tax Losses | |
| Policy Issues in the Tax Treatment of Losses | |
| Country Rules on Corporate Tax Losses | |
| Schemes Involving Tax Losses | |
| Strategies for Detecting Schemes Involving Tax Losses | |
| Strategies for Responding to Schemes Involving Tax Losses | |
| Conclusions and Recommendations | |
| References | |
| Annex A - Size of loss carry-forwards compared to loss carry-forwards in percentage of gross domestic product |
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