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OverviewThe rise of multinationals and their ability to engage in sophisticated cross-border tax planning have governments and policymakers struggling to deal with the implications. Currently, governments commonly utilise corporate interest limitation rules since they are widely perceived as an anti-avoidance mechanism that limits tax base erosion. Despite this perception, the legal basis for these rules does not reconcile with the economic basis because they present only imperfect solutions to the problem of the ‘debt bias’.Taxing Multinationals considers whether equalising the tax deductibility of fungible intercompany funding activities would minimise opportunities for cross-border tax planning by multinationals. It approaches the issue of thin capitalisation by conceptualising the cross-border debt bias as the ‘disease’ and thin capitalisation as merely the ‘symptom’. It then explores whether the ‘disease’ would be better addressed by retaining interest limitation rules in their current form or if an alternative reform would be more effective. Full Product DetailsAuthor: Ann Kayis-Kumar (Lecturer in the School of Taxation and Business Law, Lecturer in the School of Taxation and Business Law, University of New South Wales, Australia)Publisher: Oxford University Press Australia Imprint: OUP Australia and New Zealand Dimensions: Width: 16.00cm , Height: 1.80cm , Length: 24.00cm Weight: 0.542kg ISBN: 9780190319311ISBN 10: 0190319313 Pages: 260 Publication Date: 20 March 2019 Audience: Professional and scholarly , College/higher education , Professional & Vocational , Tertiary & Higher Education Format: Paperback Publisher's Status: Active Availability: To order  Stock availability from the supplier is unknown. We will order it for you and ship this item to you once it is received by us. Table of ContentsIntroductionReviewing the Theoretical and Applied LiteraturesDesigning a Principles-Based Evaluation FrameworkEvaluating Current Legal Practice on Cross-Border Intercompany DeductionsSimulating Tax-Minimising Behavioural Responses to Current and Proposed Tax RulesDeveloping Principles-Based Proposals for Tax ReformResults and ConclusionReviewsAuthor InformationAnn Kayis-Kumar is a Lecturer in the School of Taxation and Business Law at UNSW. Tab Content 6Author Website:Countries AvailableAll regions |
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