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National tax laws have not kept pace with the globalisation of corporations and the digital economy, leaving gaps that can be exploited by multi-national corporations to artificially reduce their taxes.
Aggressive tax planning (ATP) schemes based on after-tax hedging pose a threat to countries’ revenue base. Empirical evidence suggests that hundreds of millions of USD are at stake, with a number of multi-billion transactions identified by countries.
While after-tax hedging is not, of itself, aggressive - being generally a straightforward risk management technique - the report recognises that it can also be used as a feature of aggressive tax planning (ATP) schemes. ATP schemes based on after-tax hedging pose a threat to countries’ revenue base.
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Dispositifs Hybrides: Questions de politique et de discipline fiscales
The OECD's work on Aggressive Tax Planning focuses on helping tax authorities to respond more quickly to tax risks, to identify trends and patterns already identified and experienced by some tax administrations, and to share experiences in dealing with them
Aggressive tax planning – untaxed income, multiple deductions and other forms of international tax arbitrage - is a growing concern for all governments.
Aggressive Tax Planning is an increasing source of concern for many governments. This report describes the most common types of hybrid mismatch arrangements (i.e. arrangements exploiting differences in the tax treatment of instruments, entities or transfers between two or more countries) and the effects they aim to achieve. It summarises the tax policy issues raised by these arrangements and describes the policy options to address
Officials from revenue bodies, the banking sector and OECD met in Rome on 10-11 October to discuss ways to enhance the relationship between tax administrations and the banking industry and thus improve tax compliance.
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
The 2011 OECD report, "Tackling Aggressive Tax Planning through Improved Transparency and Disclosure".