Tax law and the transfer of losses a European overview and categorization Anna Theresa Bührle & Christoph Spengel
By: Bührle, Anna Theresa
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Contributor(s): Spengel, Christoph.
Material type: 
ArticlePublisher: 2020Subject(s): SOCIEDADES | EMPRESAS | PERDIDAS | IMPUESTOS | SOCIEDADES INTERPUESTAS | UNION EUROPEA
In:
Intertax v. 48, Issues 6-7, June / July 2020, p. 564-581Summary: Loss trafficking is the acquisition of shell companies with significant tax loss carry forwards but without any economic activity or for no other purpose than the transfer of tax loss carryforwards. This study provides an overview over the design and development of loss transfer restrictions in the 28 EU countries over a time period of nineteen years (2000-2018). Different aspects of the regulations are analysed against the background of their impact on start-ups. Finally, the rules are categorized with respect to their strictness. Over time, more countries introduced restrictions. Simultaneously, the regulations became more lenient, offering start-ups more opportunities to maintain their loss carryforwards and, therefore, decreasing the risk for investors.
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| Artículos | IEF | IEF | OP 2141/2020/6/7-3 (Browse shelf) | Available | OP 2141/2020/6/7-3 |
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| OP 2141/2020/6/7 Intertax | OP 2141/2020/6/7-1 Covid-19 | OP 2141/2020/6/7-2 What is international double taxation? | OP 2141/2020/6/7-3 Tax law and the transfer of losses | OP 2141/2020/6/7-4 In pursuit of fair tax competition | OP 2141/2020/6/7-5 Place of effective management in the digital economy | OP 2141/2020/6/7-6 The use of paragraphs 1.119 to 1.128 of the 2017 OECD Transfer Pricing Guidelines for the application of transfer pricing rules |
Resumen.
Loss trafficking is the acquisition of shell companies with significant tax loss carry forwards but without any economic activity or for no other purpose than the transfer of tax loss carryforwards. This study provides an overview over the design and development of loss transfer restrictions in the 28 EU countries over a time period of nineteen years (2000-2018). Different aspects of the regulations are analysed against the background of their impact on start-ups. Finally, the rules are categorized with respect to their strictness. Over time, more countries introduced restrictions. Simultaneously, the regulations became more lenient, offering start-ups more opportunities to maintain their loss carryforwards and, therefore, decreasing the risk for investors.
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