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Table V reports information on the size of MNE groups filing CbCRs. For the purposes of Table V, the size of an MNE group is defined in terms of three variables: 1. Unrelated Party Revenues 2. Number of Employees 3. Tangible Assets other than Cash and Cash Equivalents. The total size of an MNE...
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In Table III data is shown by the effective tax rate of the MNE group and by tax jurisdiction. The effective tax rate of an MNE Group is computed by summing Income Tax Accrued – Current Year across all subgroups reported on a CbCR. Then group-level profit (loss) is computed in a similar...
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In Table IV data is shown by the effective tax rate of the MNE sub-group and by tax jurisdiction. The effective tax rate of an MNE sub-group is computed by dividing the sub-group income tax accrued by the sub-group-profit (loss).
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Aggressive tax planning (ATP) schemes based on after-tax hedging pose a threat to countries’ revenue base: empirical … 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 …
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The similarities and differences between the transition experiences of the Central European countries and the People's Republic of China are often, wrongly, taken as alternative approaches to the same problem. In reality, there is great complexity, not only in the environments of these two great...
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