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 USD transactions identified by certain countries. After having described in general terms the notion of hedging as a risk management tool and the effect of taxation on hedging transactions, this report illustrates the features of ATP schemes based on after-tax hedging, summarises the detection and response strategies that have been used by countries, highlights the compliance and policy issues arising from these schemes, and ends with a number of conclusions and recommendations.
