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So, best I can tell, neither the OECD's base erosion and profit shifting work nor the U.S. [TCJA] tax reform, will end the ability of major U.S. companies to reduce their overall tax burden by aggressively shifting profits offshore (and paying between 0 [and] 3 percent on their offshore profits and then being taxed at the GILTI 10.5 percent ...
The OECD G20 Base Erosion and Profit Shifting Project (or BEPS Project) is an OECD/G20 project to set up an international framework to combat tax avoidance by multinational enterprises ("MNEs") using base erosion and profit shifting tools. [5]
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, sometime abbreviated BEPS multilateral instrument, is a multilateral convention of the Organisation for Economic Co-operation and Development to combat tax avoidance by multinational enterprises (MNEs) through prevention of Base Erosion and Profit Shifting (BEPS).
Base erosion and profit shifting; List of countries by tax rates for a comparison of corporate tax rates around the world, and Tax rates in Europe for just the continent; Corporate haven, a country with low effective tax rates for corporations; World taxation system; International taxation
Ireland's base erosion and profit shifting (BEPS) tools give some foreign corporates § Effective tax rates of 0% to 2.5% [b] on global profits re-routed to Ireland via their tax treaty network. [c] [d] Ireland's aggregate § Effective tax rates for foreign corporates is 2.2–4.5%. Ireland's BEPS tools are the world's largest BEPS flows ...
Base erosion and profit shifting ("BEPS"). Hines-Rice showed U.S. multinationals were using non-traditional tax havens, like Ireland and Singapore, that had large networks of tax treaties (which traditional tax havens are restricted from having), enabling them to avoid corporate taxes in all jurisdictions that had tax treaties with the haven ...
The organisation also attempted to limit companies’ ability to shift profits to low-tax locations, a practice known as base erosion and profit shifting (BEPS). [1] [2] The goal of this worldwide exchange of tax information being tax transparency, it requires the exchange of a significant volume of information.
However, tax planning under separate accounting focuses on tax base shifting whereas tax planning under formula apportionment focuses on the location of investments. All proposals eliminate profit shifting by means of transfer pricing or financing. Basically, formula apportionment works like a tax on each factor included in the formula.