Substance : Aligning international tax planning with today's business realities
Publication : juin 2009
Edition : Edited by PwC Tax & Legal
Contact(s) : Pierre Escaut, Renaud Jouffroy
Prix : € 175 plus shipping
This book comes at a moment when we are facing the most important global economic challenges in recent history. The current downturn has caused policy makers in various countries to question tax planning by multinational company groups from a mere “morality” perspective, considering the negative consequences for government budgets, which are under ever greater pressure. It is likely that legislation will be passed at various levels, allowing tax authorities around the globe to more effectively challenge tax structures which are perceived as artificial. Tax planning without appropriate economic substance is therefore under big pressure.
The book addresses exactly this need for the proper monitoring of economic substance in the context of corporate structures (for the tax residency of companies and beneficial ownership of income flows) and in the context of operating models (for the transfer pricing of goods, services and intangibles among entities marked by some form of economic solidarity). It also considers the domestic tax rules in 44 countries around the globe and reviews how they interact with the OECD rules (double tax treaties, transfer pricing guidelines) and EU law.
Substance: Aligning international tax planning with today's business realities can provide guidance to taxpayers everywhere to review whether their tax strategy is sufficiently solid to deal with increased scrutiny by tax authorities.
By Axel Smits and Isabel Verlinden from PwC Belgium
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