Transcription of THIN CAPITALISATION LEGISLATION A BACKGROUND …
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1 THIN CAPITALISATION LEGISLATION A BACKGROUND PAPER FOR COUNTRY TAX ADMINISTRATIONS (Pilot version for comments) Initial draft - August 2012 2 THIN CAPITALISATION Introduction This paper, which has been prepared by the OECD Secretariat for training purposes, aims to assist country tax administrations that are considering revising their existing thin CAPITALISATION rules, or introducing thin CAPITALISATION rules for the first time. The paper aims to: describe what is meant by thin CAPITALISATION explain why many countries take measures to address thin CAPITALISATION in their tax rules describe the legislative approaches that countries frequently adopt to such rules address some of the issues th
Depending on the exact wording of the relevant legislation, an arm’s length approach to thin capitalisation may be achieved through a country’s general transfer pricing rules. An arm’s length approach may also allow elimination of double taxation through the application
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