Interest deductions and tax avoidance – will BEPS solve the problem? http://www.taxjustice.net/2017/10/05/interest-deductions-and-tax-avoidance-will-beps-solve-the-problem/ …pic.twitter.com/cJDrNguZLw
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The fixed ratio in the BEPS action is total debt. Both intra-company and external.
Your dodgyco example & S&P leverage ratios etc on external debt. What light does that shed on Qs on use of intracompany debt?
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It is answering one question, does the BEPS action deal with this. It is saying that the cap is set so high that the action is meaningless.
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The article leads with "MNCs can set up finance companies in tax havens to loan money to their operating companies around the world"
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