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An analysis by Tax Partner AG, Taxand Switzerland
The International Fiscal Association Cancun has recently published a report analysing the latest developments in international tax law in the Cahiers de Droit Fiscal International, Vol. 107. Professor René Matteotti from our Swiss firm, Tax Partner AG, has contributed to Subject 1, “Sharing and Shifting of Corporate Losses – The New Profit Shifting?”.
He examines the impact of corporate losses on tax revenues during economic downturns, highlighting global variations in regulations, especially in group taxation systems and methods for handling losses from foreign branches. The findings include inadequacies in loss offset regimes, temporary legislative changes due to the Covid-19 crisis, and challenges related to loss shifting and artificial loss creation. Despite concerns, the report concludes that corporate loss sharing and shifting is not the new profit shifting, based on evidence from branch reports.
For a comprehensive read of Professor Matteotti’s full General Report please click here.
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