Thin Capitalization Rules in EU Member States

Thin capitalization rules fit in the group of the specific anti-avoidance rules (SAAR) which are legalised by domestic tax laws. Anti-avoidance measures attempt to strike down unacceptable tax avoidance practices that have taken place with the increasing importance of multinational firms. In contras...

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Main Author: Tatjana Ðukić
Format: Article
Language:English
Published: University of Ljubljana Press (Založba Univerze v Ljubljani) 2011-06-01
Series:Central European Public Administration Review
Subjects:
Online Access:https://journals.uni-lj.si/CEPAR/article/view/20334
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author Tatjana Ðukić
author_facet Tatjana Ðukić
author_sort Tatjana Ðukić
collection DOAJ
description Thin capitalization rules fit in the group of the specific anti-avoidance rules (SAAR) which are legalised by domestic tax laws. Anti-avoidance measures attempt to strike down unacceptable tax avoidance practices that have taken place with the increasing importance of multinational firms. In contrast to local firms, multinational corporations can shift profits to lower taxed foreign locations, leading to substantial losses in tax revenue. The article presents a systematic review of thin capitalization rules in EU 27, summing up four most common approaches of thin capitalization regulation. The analysis revealed that the majority of countries (15) legalised the fixed ratio approach, one quater (7) the subjective approach and only a few (3) legalised the hidden profit distribution. Two of them have improved thin-cap rules to so called earningstripping rule.
format Article
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institution Kabale University
issn 2591-2240
2591-2259
language English
publishDate 2011-06-01
publisher University of Ljubljana Press (Založba Univerze v Ljubljani)
record_format Article
series Central European Public Administration Review
spelling doaj-art-50058c3f72d04b1eb8463539ef17159b2025-01-22T10:55:19ZengUniversity of Ljubljana Press (Založba Univerze v Ljubljani)Central European Public Administration Review2591-22402591-22592011-06-019210.17573/cepar.v9i2.177Thin Capitalization Rules in EU Member StatesTatjana ÐukićThin capitalization rules fit in the group of the specific anti-avoidance rules (SAAR) which are legalised by domestic tax laws. Anti-avoidance measures attempt to strike down unacceptable tax avoidance practices that have taken place with the increasing importance of multinational firms. In contrast to local firms, multinational corporations can shift profits to lower taxed foreign locations, leading to substantial losses in tax revenue. The article presents a systematic review of thin capitalization rules in EU 27, summing up four most common approaches of thin capitalization regulation. The analysis revealed that the majority of countries (15) legalised the fixed ratio approach, one quater (7) the subjective approach and only a few (3) legalised the hidden profit distribution. Two of them have improved thin-cap rules to so called earningstripping rule.https://journals.uni-lj.si/CEPAR/article/view/20334thin capitalizationtax revenueanti-avoinance rulesEUtax authority
spellingShingle Tatjana Ðukić
Thin Capitalization Rules in EU Member States
Central European Public Administration Review
thin capitalization
tax revenue
anti-avoinance rules
EU
tax authority
title Thin Capitalization Rules in EU Member States
title_full Thin Capitalization Rules in EU Member States
title_fullStr Thin Capitalization Rules in EU Member States
title_full_unstemmed Thin Capitalization Rules in EU Member States
title_short Thin Capitalization Rules in EU Member States
title_sort thin capitalization rules in eu member states
topic thin capitalization
tax revenue
anti-avoinance rules
EU
tax authority
url https://journals.uni-lj.si/CEPAR/article/view/20334
work_keys_str_mv AT tatjanaðukic thincapitalizationrulesineumemberstates