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Action Plan 5 – Counter Harmful Tax Practices - International Taxation - Income TaxExtract ..... eferential regimes since its creation in 1998 in order to determine if the regimes could be harmful to the tax base of other jurisdictions. The current work of the Forum on Harmful Tax Practices (FHTP) comprises three key areas. Firstly, the assessment of preferential tax regimes to identify features of such regimes that can facilitate base erosion and profit shifting, and therefore have the potential to unfairly impact the tax base of other jurisdictions. Secondly, the peer review and monit ..... x x x x x Extracts x x x x x Action Plan 5 Counter Harmful Tax Practices - International Taxation - Income Tax x x x x x Extracts x x x x x ..... tion 5 is not limited to exchanging information on rulings related to preferential regimes but allows for broader transparency. Six Categories of Rulings are rulings relating to preferential regimes; unilateral APAs or other cross-border unilateral rulings in respect of transfer pricing; cross-border rulings providing for a downward adjustment of taxable profits; permanent establishment (PE) rulings; related party conduit rulings; and any other type of ruling agreed by the FHTP that ..... x x x x x Extracts x x x x x Action Plan 5 Counter Harmful Tax Practices - International Taxation - Income Tax x x x x x Extracts x x x x x ..... al tax jurisdictions to the jurisdictions in which the immediate and ultimate parent and the beneficial owners of the entities are resident but also enable receiving tax administrations to carry out risk assessments and to apply their controlled-foreign company, transfer pricing and other anti-base erosion and profit shifting provisions. In order to ensure the effectiveness of the NTJ standard in practice, the FHTP is carrying out annual monitoring of the compliance of the 12 no or only nominal ..... x x x x x Extracts x x x x x Action Plan 5 Counter Harmful Tax Practices - International Taxation - Income Tax x x x x x Extracts x x x x x
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