Limitations on interest deductions: does BEPS action 4 presume tax avoidance?
Debt and equity are in most countries treated differently for taxing purposes. The asymmetry between the financing forms are being taken advantage of by MNEs, allowing them to plan their cross-border activities in a way that lowers the taxable burden for the whole group. To prevent the increasing problem of base erosion and profit shifting, Member States have implemented different rules limiting i