The Taxation of global trading of financial instruments. / Organisation for Economic Co-operation and Development.

Format:

Book

Author/Creator:

Organisation for Economic Co-operation and Development, author.

Contributor:

Organisation for Economic Co-operation and Development Special Sessions on Innovative Financial Transactions., Content Provider.

Organisation for Economic Co-operation and Development Committee on Fiscal Affairs, Content Provider.

Series:

Documents

OECD documents The Taxation of global trading of financial instruments.

Language:

English

Subjects (All):

Financial instruments--Taxation.

Financial instruments.

Physical Description:

1 online resource (72 p. )

Place of Publication:

Paris, France : Organisation for Economic Co-operation and Development, [1998]

Language Note:

English

Summary:

Technological change and financial deregulation have dramatically globalised financial markets. Financial firms have developed innovative financial instruments, such as swaps and derivatives, to meet the often different global demand of investors and borrowers and have organised themselves to sell such global financial products 24 hours a day. This phenomenon of global trading challenges tax payers and tax administrations to come up with a fair way of allocating and taxing the profits in each country where global trading is carried on. This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems. Although the paper discusses a specific industry sector, many of the issues raised, for example the high level of global integration of functions and intensive co-operation between different geographic locations, are becoming more common in other industries with the spread of globalisation and the communications revolution.

Contents:

EXECUTIVE SUMMARY

GLOSSARY

I. INTRODUCTION

II. CURRENT SITUATION

II - 1. Business background

II - 2. Factors affecting structure of the business

II - 3. Organisation of trading activities

II - 4. Functional analysis

II - 5. Risk of double or less than single taxation

III. THE APPLICATION OF THE ARM’S LENGTH PRINCIPLE

III - 1. General application and methods

III - 2. Analysis of global trading functions

III - 3. Profit split methods

IV. DETERMINATION OF THE PROFIT TO BE SPLIT FROM GLOBAL TRADING

IV - 1. The scope of activities and revenues to be included in the profit split

IV - 2. Net or gross profit split and deduction of expenses

IV - 3. Calculation of the amount of profits

V. APPLICATION OF THE ARM’S LENGTH PRINCIPLE TO GLOBAL TRADING CONDUCTED IN A BRANCH FORM

V - 1. Preparatory or auxiliary activities/mere purchase

V - 2. Agents

V - 3. Attribution of income

V - 4. Treatment of internal payments

VI. CONCLUSION

NOTES AND REFERENCE

Notes:

Description based on print version record.

Prepared by the Special Sessions on Innovative Financial Transactions, appointed by the OECD Committee on Fiscal Affairs.

"A revised and updated version of the discussion draft ... released on the 14th February 1997."

Includes bibliographical references.

ISBN:

1-280-02964-1

9786610029648

92-64-16249-6

OCLC:

1024267768