The present publication is concerned with the process of thin capitalisation in the countries of OECD. Two methods for financing companies are discerned in relation to this phenomenon, i.e. debt and equity financing. The tax-related consequences of the method of equity financing of companies are...

The following paper explores the issue of thin capitalisation in Organisation for Economic Co-operation and Development (OECD) member countries. There are two methods used by financing companies that are strongly related to this phenomenon: debt and equity financing. The tax-related consequences...

The COVID-19 pandemic has forced governments to take unprecedented measures such as restricting travel and implementing strict quarantine requirements. In this difficult context, most countries are putting stimulus packages in place, including measures to support employment, for example, taking...

The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the...

The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the...

This publication brings together two reports prepared by the Committee on Fiscal Affairs. The first, "Thin Capitalisation", examines the implications for taxation of the different reliance by companies on debt and equity financing. The second, "The Taxation of Income Derived from Entertainment,...

This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and...