Which interest deduction limitation technique is the preferred tool, as related in BEPS action 4?
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Michael Kalson, PhD
BEPS Action 4 aims to limit base erosion and profit shifting caused by differing interest deduction allowances among varying jurisdictions in which multinational enterprises operate by recommending that countries implement a “fixed ratio” rule that would limit net interest deductions claimed by an entity to a fixed percentage of earnings before interest, taxes, depreciation and amortization (EBITDA) that is somewhere between 10% and 30% of applicable EBITDA.
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297 weeks ago