Planification fiscale agressive

Corporate Loss Utilisation through Aggressive Tax Planning


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Publication Date: 12/08/2011
Pages: 92

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.

 Press Release


01/09/2011 - Corporate losses and aggressive tax planning: A source of increasing


  Table of Contents



Executive Summary


Chapter 1. Size of Corporate Tax Losses

Chapter 2. Policy Issues in the Tax Treatment of Losses

Chapter 3. Country Rules on Corporate Tax Losses

Chapter 4. Schemes Involving Tax Losses

Chapter 5. Strategies for Detecting Schemes Involving Tax Losses

Chapter 6. Strategies for Responding to Schemes Involving Tax Losses

Conclusions and Recommendations


Annex A. Graphs showing size of loss carry forwards compared to loss carry forwards as a percentage of GDP for ten countries


 How to obtain this publication




Click here to see an overview of the report.


 More information


For further information, please contact Achim Pross  ( or Raffaele Russo ( from the Centre for Tax Policy and Administration.



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