Worldwide interest cap: Difference between revisions
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imported>Doug Williamson (Create the page. Source: The Treasurer, June 2015, page 10, Technical Briefing.) |
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''Tax'' | ''Tax''. | ||
A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative. | A proposal under the OECD's [[Base erosion and profit shifting]] (BEPS) initiative. |
Revision as of 20:24, 15 June 2015
Tax.
A proposal under the OECD's Base erosion and profit shifting (BEPS) initiative.
The worldwide interest cap method is a proposed methodology to limit tax relief for interest and amounts economically equivalent to interest.
It would limit the total amounts eligible for relief to a cap equal to the total of a taxpayer group's net third party interest expense.
The total cap would then be allocated by territory through an appropriate allocation key, for example territory profits as a proportion of total group profits.
An alternative proposed methodology is a fixed-ratio method.