New PDF release: Addressing Tax Risks Involving Bank Losses

By OECD

The monetary and monetary drawback had a devastating impression on financial institution gains, with loss-making banks reporting international advertisement losses of round USD four hundred billion in 2008.  This entire file units the industry context for financial institution losses and gives an outline of the tax remedy of such losses in 17 OECD nations; describes the tax dangers that come up on the subject of financial institution losses from the point of view of either banks and profit our bodies; outlines the incentives that provide upward thrust to these hazards; and describes the instruments profit our bodies need to deal with those power compliance hazards. It concludes with innovations for profit our bodies and for banks on how hazards related to financial institution losses can most sensible be controlled and lowered. desk of content material :ForewordExecutive SummaryChapter 1. atmosphere the context for present degrees of financial institution tax lossesChapter 2. power scale/fiscal expense of banks tax lossesChapter three. precis of kingdom ideas when it comes to taxation of financial institution lossesChapter four. major matters for banks relating to tax lossesChapter five. Compliance/tax possibility matters for profit our bodies when it comes to financial institution tax lossesChapter 6. instruments on hand to profit our bodies to deal with compliance dangers relating to financial institution tax lossesChapter 7. Conclusions and recommendationsAnnex A. kingdom ideas with regards to taxation of financial institution lossesGlossary of acronyms and technical phrases

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Country tax treatment of banks’ write-downs and write-offs of loans and securities Country rules differ in the extent to which write-downs or write-offs of loans are tax deductible. With certain limitations, most participating countries allow the deduction for tax purposes of write-downs on loans. For a writedown to be allowed as a deduction for tax purposes, some countries require that the loss in value of the loan must be certain. In others, appropriately calculated impairment losses recognised in the accounts are allowed for tax purposes, but not general bad debt provisions.

Html. ADDRESSING TAX RISKS INVOLVING BANK LOSSES © OECD 2010 3. SUMMARY OF COUNTRY RULES IN RELATION TO TAXATION OF BANK LOSSES – 31 Chapter 3. Summary of country rules in relation to taxation of bank losses Abstract This chapter summarises relevant country tax rules relating to bank losses. These include rules for how losses are recognised for tax purposes as well as rules for how tax relief may be given in respect of such losses. The rules are complex, and differ from country to country, and the chapter aims to summarise the key elements under a number of themes, including the tax treatment of the write-down of loans and securities, rules for offsetting tax losses against other income of the same company, rules for offsetting tax losses within a group of related companies, rules for the carry-over of unrelieved tax losses, rules for the treatment of foreign losses and restrictions on tax relief for a loss being given more than once.

E. by not properly accounting for the decrease in value arising from the embedded losses when it is attributed to the Australian branch), or (c) the third party liability without attributing to the branch adequate compensation for the value of the liability assumed by the branch. As a result of the arrangements, greater deductions for losses are sought in Australia by the Australian branch or subsidiary. e. where a company in country A holds a hedging instrument for the benefit of the group as a whole in relation to an asset or liability of an associated company in country B.

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