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By Oliver R. Hoor (picture) and Keith O’Donnell, ATOZ *
On 18 December 2014, the OECD released a discussion draft (the “Discussion Draft”) on Action 4 of the Base Erosion and Profit Shifting (“BEPS”) Action Plan relating to interest deductions and other financial payments for public consultation. More than 1,000 pages of public comments have been provided by multinationals, business associations and other interested parties on the Discussion Draft that considers approaches to limit the deductibility of interest (and other financial payments). This article provides a critical overview of the proposals in the Discussion Draft and considers the potential impact on cross-border business activities and investment.
I. Introduction
The...
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