improves improves fairness. fairness. However, However, submitters this option have argued excludes all that in some deferred tax instances yet, in – deferred tax many does not instances, represent a deferred tax real liability. will To the represent a extent this is future tax correct, payment a including taxpayer will deferred tax be required in the to make. To liability the extent adjustment this is the be seen case, this as unfair. option will not treat taxpayers in the same situation the same. 0 Efficiency of 0 compliance Neither option will have a significant impact on compliance costs. The result of both options is just a change to how the existing thin capitalisation calculations are carried out. However, there may be some one-off compliance costs if the changes mean taxpayers breach their thin capitalisation limits and, as a result, decide to restructure their borrowing.
improves fairness. However, submitters have argued that in some instances deferred tax does not represent a real liability. To the extent this is correct, including deferred tax in the liability adjustment be seen as unfair. improves fairness. However, this option excludes all deferred tax – yet, in many instances, deferred tax will represent a future tax payment a taxpayer will be required to make. To the extent this is the case, this option will not treat taxpayers in the same situation the same. Efficiency of compliance 0 Neither option will have a significant impact on compliance costs. The result of both options is just a change to how the existing thin capitalisation calculations are carried out. However, there may be some one-off compliance costs if the changes mean taxpayers breach their thin capitalisation limits and, as a result, decide to restructure their borrowing. 0
2017-other-beps-16-ria-interest-july-2017.docx