Corporate losses raise compliance risks if aggressive tax planning is used as a means
of increasing or accelerating tax relief in ways not intended by the legislator, or
to generate artificial losses. This report describes the size of loss carry-forwards,
the rules applicable in relation to losses, and identifies the following risk areas:
corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
After having summarised aggressive tax planning schemes on losses, as well as country
detection and response strategies, it offers a number of conclusions and recommendation
for tax administration and tax policy officials.