International Tax Structures in the BEPS Era: An analysis of anti-abuse measures

International Tax Structures in the BEPS Era: An Analysis of Anti-Abuse Measures
This book is essential reading for anyone dealing with tax structuring schemes and anti-abuse provisions in daily practice, including tax practitioners, tax authorities and policymakers.

Why this book?

Tax planning structures used by some MNEs have become the bane of policymakers nowadays, at the OECD as well as the EU level, since recent statistics revealed public budgets were deprived of billions of euros.

Within the context of recent developments in the tax arena, this book examines the anti-abuse measures that already exist in various countries and scrutinizes the effectiveness of these measures in countering aggressive tax structures. This work can be considered complementary to the reports issued or to be issued by the OECD, and to the recent activity at the EU level, as it provides an in-depth analysis of what is already happening in practice in various countries when they encounter abusive tax structures. It also highlights the challenges implicit in the recommended measures in the draft reports issued by the OECD up until 1 May 2015, with some exceptions.

The book provides the reader with an analysis of the most common strategies against tax avoidance; the key concepts in international tax structuring, such as the use of permanent establishments and the exploitation of transfer pricing rules; and the intricacies of anti-abuse measures that counter tax structuring schemes used for financing activities and for selected business models, specifically related to supply chain management, IP migration and exploitation, the digital economy and holding companies.


Sample excerpt, including table of contents

This book is part of the IBFD Tax Research Series

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Madalina Cotrut


Laura Ambagtsheer-Pakarinen, Anuschka J. Bakker, Aleksandra Bal, Boyke Baldewsing, Rijkele Betten, Shee Boon Law, Madalina Cotrut, Carlos Gutiérrez, Ridha Hamzaoui, Marjolein Kinds, Monia Naoum, René Offermanns, Lydia G. Ogazón Juárez, Andreas Perdelwitz, Oana Popa, Ruxandra Vlasceanu.

International Tax Structures in the BEPS Era: An Analysis of Anti-Abuse Measures
Chapter 1: Common Strategies against Tax Avoidance: A Global Overview
Chapter 2: Permanent Establishments in International Tax Structuring
Chapter 3: Transfer Pricing from the Perspective of Substance and Transparency: Is the OECD on the Right Track?
Chapter 4: Anti-Base-Erosion Measures for Intra-Group Debt Financing
Chapter 5: Hybrid Instruments in the Post-BEPS Era
Chapter 6: Past, Present and Future of Tax Structuring Using Hybrid Entity Mismatches
Chapter 7: Business Restructurings: The Toolkit for Tackling Abusive International Tax Structures
Chapter 8: Intellectual Property Structuring in the Context of the OECD BEPS Action Plan
Chapter 9: Taxation of the Digital Economy
Chapter 10: International Tax Structuring for Holding Activities

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