Tax Sparing [electronic resource]: A Reconsideration / Organisation for Economic Co-operation and Development

Format:

Book

Government document

Author/Creator:

Organisation for Economic Co-operation and Development.

Contributor:

Organisation for Economic Co-operation and Development, Content Provider.

Language:

English

Subjects (All):

Taxation.

Double taxation--Treaties.

Double taxation.

Tax sparing.

Tax incentives.

Local Subjects:

Taxation.

Physical Description:

1 online resource (88 p. ) ill..

Place of Publication:

Paris : OECD Publishing, 1998.

Language Note:

English

Summary:

Tax sparing provisions have now more than four decades of history in bilateral tax treaties, including treaties between OECD countries. But the world of today is quite different from that when the positions of OECD Member and non-member countries towards tax sparing were developed. These changes in the international setting have led countries to reconsider their attitude towards tax sparing and the design of such provisions. This report examines the practices of Member countries and explains why Member countries have become more reluctant to grant tax sparing in treaties. It also provides a number of suggested "best practices" on the design of tax sparing provisions in tax treaties.

Contents:

I. Introduction

II. The Historical Development of Tax Sparing Provisions

III. Traditional Country Provisions on the Issue of Tax Sparing

IV. Tax Sparing: An Emerging Consensus on the Need for a Re-Evaluation

V. Recent Trends in Tax Sparing Provisions

VI. Best Practices in Designing Tax Sparing Provisions

VII. Recommendations

Annex I. Member Country Tax Sparing Provisions Referred to in the Report

Annex II. Tax Sparing Provisions in Treaties between OECD Member Countries

Annex III. Tax Sparing Provisions in Treaties between OECD Member and Certain Non-Member Countries

Annex IV. Tax Avoidance Scheme I

Annex V. Tax Avoidance Scheme II

Annex VI. Anti-Abuse Provisions

Annex VII. Article 23B of the Commentary to the OECD Model Tax Convention

Annex VIII. Recommendation of the Council on the Granting and Design of Tax Sparing in Tax Conventions

Bibliography

Notes:

Bibliographic Level Mode of Issuance: Monograph

ISBN:

1-280-00587-4

9786610005871

92-64-16243-7

OCLC:

652360363