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The Taxation of Offshore Indirect Transfers : a toolkit - draft version 2 (English)

The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located? (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.


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    The World Region,

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    a toolkit - draft version 2

  • Keywords

    underlying asset; capital gain; taxation of capital gains; acquisition of property right; transfer of ownership; capital gain taxation; indirect ownership interest; transfer of asset; class of asset; limitation on benefits; source of revenue; net present value; types of asset; dividend tax rate; amount of dividends; allocation of revenue; collection of tax; corporate income tax; form of taxation; withholding tax rate; tax country; types of income; taxation of rents; basis for taxation; taxable capital gain; change in control; theory of taxation; form of dividends; foreign direct investment; income tax purpose; tax treaty; direct transfer; immovable asset; tax treatment; domestic law; Extractive Industry; immovable property; rent tax; international tax; model treaty; tax jurisdiction; source country; tax system; tax from october; intellectual property; tax rule; asset transfer; efficiency considerations; indirect interest; country taxation; double taxation; primary tax; purchase price; financial asset; retained earnings; treaty provision; parent company; brand name; real asset; ownership structure; tax advantage; capital loss; foreign investor; tax benefit; empirical analysis; location-specific rents; legislative language; Natural Resources; tax consequence; tax term; interest income; tax liability; tax law; tax distortion; physical property; tax basis; geographic location; mineral right; protocol amending; cross ownership; ownership chain; corporate structure; transfer pricing; tax reduction; tax authorities; tax authority; share purchase; asset purchase; depreciation allowance; potential investor; comparative analysis; tax receipt; commodity price; domestic sale; borrowing capacity; high tax; tax due; unexpected changes; policy prescriptions; productive capacity; cross-border issue; corporate residence; capital ownership; tax incentive; tax dividend; asymmetric information; thin market; hard minerals; general agreement; tax preference; debt finance; residence country; national interest; company share; extractive resource; legislative action; harmful effect; oil companies; oil company; holding company; retroactive effect; tax matter; financial operation; tax avoidance; future dividend; taxation rights; domestic asset; Political Economy; Tax Administration; tangible asset; business environment; Tax Holiday; tax payment; domestic legislation; asset price; raise revenues; efficient tax; Public Services; corporate tax; profit shift; domestic taxation; tax instrument; tax design; efficiency criterion; international setting; estimation result; international taxation; local resident; international policy; binding rule; real property; tax issue; civil society; public comment; legal aspect; descriptive statistic; financial value; foreign enterprise; intangible property; corporate stock; contracting state; business profit; flat rate; tax levy; entity transfer; direct purchase; business asset; review period; taxable gain; taxable event



Official version of document (may contain signatures, etc)


The Taxation of Offshore Indirect Transfers : a toolkit - draft version 2 (English). The Platform for Collaboration on Tax Washington, D.C. : World Bank Group.