Addressing Tax Risks Involving Bank Losses by OECD

By OECD

The monetary and monetary hindrance had a devastating influence on financial institution gains, with loss-making banks reporting worldwide advertisement losses of round USD four hundred billion in 2008.  This entire document units the industry context for financial institution losses and offers an summary of the tax remedy of such losses in 17 OECD nations; describes the tax hazards that come up when it comes to financial institution losses from the viewpoint of either banks and profit our bodies; outlines the incentives that supply upward push to these dangers; and describes the instruments profit our bodies need to deal with those power compliance dangers. It concludes with suggestions for profit our bodies and for banks on how dangers related to financial institution losses can top be controlled and diminished. desk of content material :ForewordExecutive SummaryChapter 1. environment the context for present degrees of financial institution tax lossesChapter 2. power scale/fiscal price of banks tax lossesChapter three. precis of kingdom principles with regards to taxation of financial institution lossesChapter four. major concerns for banks when it comes to tax lossesChapter five. Compliance/tax hazard concerns for profit our bodies relating to financial institution tax lossesChapter 6. instruments to be had to profit our bodies to deal with compliance dangers in terms of financial institution tax lossesChapter 7. Conclusions and recommendationsAnnex A. kingdom ideas on the subject of taxation of financial institution lossesGlossary of acronyms and technical phrases

Show description

Read Online or Download Addressing Tax Risks Involving Bank Losses PDF

Best banking books

Chinese Stock Markets: A Research Handbook

The exponential progress of China’s inventory markets some time past decade has attracted worldwide cognizance from teachers and practitioners. The practitioner’s curiosity in chinese language markets stems from organisations; traders and fiscal associations foresee enormous merits from making an investment in China ultimately.

Offshore Finance

This e-book was once first released in 2006. it's anticipated that as much as sixty percentage of the world's funds should be positioned offshore, the place 1/2 all monetary transactions are stated to happen; notwithstanding, there's a notion that secrecy approximately offshore is inspired to obfuscate tax evasion and funds laundering.

An Introduction to the Mathematics of Financial Derivatives, Third Edition

An creation to the math of monetary Derivatives is a well-liked, intuitive textual content that eases the transition among easy summaries of monetary engineering to extra complex remedies utilizing stochastic calculus. Requiring just a uncomplicated wisdom of calculus and chance, it takes readers on a travel of complicated monetary engineering.

Contemporary Financial Intermediation, Third Edition

In modern monetary Intermediation, 3rd version, Greenbaum, Thakor and Boot supply a particular method of monetary markets and associations, proposing an built-in portrait that places details on the center. rather than easily naming and describing markets, rules, and associations as competing books do, the authors discover the never-ending subtlety and plasticity of economic associations and credits markets.

Extra resources for Addressing Tax Risks Involving Bank Losses

Sample text

Some banks are concerned that revenue body audit procedures may mean that they do not have certainty about the amount of losses available to be used in the future, even though the loss- ADDRESSING TAX RISKS INVOLVING BANK LOSSES © OECD 2010 4. MAIN ISSUES FOR BANKS IN RELATION TO TAX LOSSES – 39 making year has already been audited by the revenue body. They consider that rules restricting loss carry forward in case of change of ownership or activity may have unintended consequences in the current climate and could hamper beneficial restructuring.

As noted in the “Report on the Attribution of Profits to Permanent Establishments”,6 this raises difficult issues where the split hedges occur between associated enterprises and will be the subject of future work. In the meantime, general guidance on transactions which purport to transfer risk from one associated enterprise to another can be found in chapter IX of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD, 2010). Particular problems also arise where financial institutions use “net” hedging strategies so that it is almost impossible to trace the gain or loss from any particular transaction to the offsetting gain or loss on the customer transaction it hedges.

For example, in one country, capital gains on shares in EEA countries are exempt (and therefore capital losses are not deductible), and the technique consists in transferring the corporate residence of a loss-making company to a non-EEA country in order to benefit from the deduction of the capital loss on the planned alienation of its shares. The transfer of the corporate residence took place purely on paper, without any change in the underlying economic substance. … including techniques which anticipate likely losses or which exploit CFC rules to import losses.

Download PDF sample

Rated 4.11 of 5 – based on 13 votes