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As globalization continues to increase, businesses are increasingly operating across borders. The growth of cross-border trade and investment has led to increased complexity in the area of international taxation. The Manual for the Control of International Tax Planning provides a comprehensive guide to help countries address the challenges of international tax planning.
The Manual for the Control of International Tax Planning is a publication by the Organisation for Economic Co-operation and Development (OECD). The OECD is an intergovernmental organization that promotes economic growth, trade, and social well-being. The Manual is designed to help tax authorities in both developed and developing countries to address the challenges posed by international tax planning.
The primary purpose of the Manual is to provide guidance on how to identify and address international tax planning schemes that are abusive and artificially shift profits to low-tax jurisdictions. The Manual aims to provide a framework for countries to develop effective rules and regulations to prevent tax avoidance and evasion.
Table of Contents
International tax planning involves the use of tax laws and regulations in different countries to minimize taxes paid by multinational corporations[1] (MNCs). MNCs may use a range of legal structures and arrangements to reduce their global tax liability.
These structures may include transfer pricing, which involves the allocation of profits and expenses between different subsidiaries of a multinational corporation. MNCs may also use tax havens, which are low-tax jurisdictions that offer favourable tax regimes to businesses. Tax havens may have little or no transparency or regulatory oversight, making them attractive to companies seeking to minimize their global tax liability.
It poses significant challenges for tax authorities around the world. The complexity of international tax planning schemes can make it difficult for tax authorities to identify and address abusive tax practices. The lack of transparency in some tax regimes and the use of tax havens can also make it challenging to trace the flow of profits and expenses between different subsidiaries of a multinational corporation.
The result is that some MNCs may pay very little tax, even though they generate significant profits from their operations in different countries. This can lead to a loss of revenue for governments, which may have to make up the shortfall through other means such as higher taxes on individuals or reductions in public services.
The Manual for the Control of International Tax Planning aims to help countries address the challenges posed by international tax planning. The Manual has several objectives:
The Manual for the Control of International Tax Planning is a comprehensive document that provides guidance to tax administrations on how to effectively control international tax planning. It is based on the latest international tax standards, such as the OECD’s Base Erosion and Profit Shifting (BEPS) project and provides a framework for identifying and combating tax avoidance and evasion.
The key features of the Manual for the Control of International Tax Planning include:
The Manual for the Control of International Tax Planning provides a number of benefits to tax administrations and taxpayers alike. These benefits include:
Here are the key points of each part of the Manual for the Control of International Tax Planning:
The Manual for the Control of International Tax Planning is an important tool for tax administrations seeking to control international tax planning and combat tax avoidance and evasion. It provides guidance on best practices for risk assessment, exchange of information, transfer pricing, anti-abuse measures, and mutual agreement procedures, based on the latest international tax standards. By adopting the measures outlined in the manual, tax administrations can increase transparency, improve international cooperation, improve tax administration, and reduce tax avoidance and evasion. Ultimately, this can help ensure that taxpayers pay their fair share of taxes and contribute to the well-being of society as a whole.
Also Read: The Principles of International Tax Planning
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