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The taxation of cross-border corporate structures is highly topical. Companies such as Starbucks, Google and Amazon have become the centre of a great deal of unwanted attention. Governments faced with depressed economies and falling tax revenues have turned their attention to what they perceive as a growing trend for multinational companies to push their activities into low or no tax jurisdictions. This perception led to the G20 asking the OECD to create an action plan that culminated in July 2013 with the publication of the OECD Action Plan on Base Erosion and Profit Sharing. In all the Report identifies 15 areas for action that are likely to dramatically change the tax landscape for companies and businesses operating in the global economy.
Despite this backdrop of uncertainty and the threat of increasingly complex rules with penalties for those companies which move jobs and economic activity elsewhere in a manner deemed to be unacceptable, companies will continue to trade in the global economy and across borders. This requires more than ever before not only detailed evaluation and comparison of the tax benefits and incentives available in competing jurisdictions, but also consideration of the tax consequences of moving capital and income flows across international borders.
The aim of this book is to provide a starting point for readers, and to assist businesses and advisers by providing topical and current insights from leading experts on the tax issues and opportunities in their respective jurisdictions (or, in one case, in the European Union). While specific tax advice is always essential, it is also necessary to have a broad understanding of the nature of the potential issues and advantages that lie ahead; this book provides a guide to these.