The Taxation of global trading of financial instruments
Technological change and financial deregulation have dramatically globalised financial markets. Financial firms have developed innovative financial instruments, such as swaps and derivatives, to meet the often different global demand of investors and borrowers and have organised themselves to sell s...
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| Corporate Authors: | , , |
| Format: | eBook |
| Language: | Inglés |
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Paris, France :
Organisation for Economic Co-operation and Development
[1998]
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| Series: | Documents
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| Subjects: | |
| See on Biblioteca Universitat Ramon Llull: | https://discovery.url.edu/permalink/34CSUC_URL/1im36ta/alma991009705214106719 |
Table of Contents:
- EXECUTIVE SUMMARY
- GLOSSARY
- I. INTRODUCTION
- II. CURRENT SITUATION
- II - 1. Business background
- II - 2. Factors affecting structure of the business
- II - 3. Organisation of trading activities
- II - 4. Functional analysis
- II - 5. Risk of double or less than single taxation
- III. THE APPLICATION OF THE ARM’S LENGTH PRINCIPLE
- III - 1. General application and methods
- III - 2. Analysis of global trading functions
- III - 3. Profit split methods
- IV. DETERMINATION OF THE PROFIT TO BE SPLIT FROM GLOBAL TRADING
- IV - 1. The scope of activities and revenues to be included in the profit split
- IV - 2. Net or gross profit split and deduction of expenses
- IV - 3. Calculation of the amount of profits
- V. APPLICATION OF THE ARM’S LENGTH PRINCIPLE TO GLOBAL TRADING CONDUCTED IN A BRANCH FORM
- V - 1. Preparatory or auxiliary activities/mere purchase
- V - 2. Agents
- V - 3. Attribution of income
- V - 4. Treatment of internal payments
- VI. CONCLUSION
- NOTES AND REFERENCE
