Action 5 agreement on modified nexus approach for ip regimes

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To Open the Box or to Close the Box? 'Patent Box' Regimes in the EU Between

Conceptual issues The Action 5 Paper notes the general acceptance of the nexus approach, subject to modifications relating to the level of qualifying expenditure, grandfathering provisions, and the tracking and tracing of expenditure.One of the documents, titled Action 5: Agreement on Modified Nexus Approach for IP Regimes (the Action 5 Paper), describes the consensus on the approach for a substantial activity requirement for intangible property (IP) regimes such as patent boxes in connection with BEPS Action 5 (harmful tax practices). 2.Implications Companies that are benefiting from IP regimes should continue to monitor OECD developments with respect to Action 5 and, more specifically, the discussion surrounding a substantial activity requirement and the agreed approach with respect to IP regimes.Timing, grandfathering and reporting issues The Action 5 Paper states that under the agreement there can be no new entrants to any existing regime after the date that a new regime consistent with the modified nexus approach takes effect and, in any event, no later than 30 June 2016.|taxguide=WCTG, S01, S08, S03; country=OECD; releasedate=2015-02-09;.Replace only this sentence with the first sentence of tax alert

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This is usually caused by different threads using the same instance of DbContext, however instance members are not guaranteed to be thread safe.This could also be caused by a nested query being evaluated on the client, if this is the case rewrite the query avoiding nested invocations.This could also be caused by a nested query being evaluated on the client, if this is the case rewrite the query avoiding nested invocations.This is usually caused by different threads using the same instance of DbContext, however instance members are not guaranteed to be thread safe.This could also be caused by a nested query being evaluated on the client, if this is the case rewrite the query avoiding nested invocations.This is usually caused by different threads using the same instance of DbContext, however instance The OECD's Nexus Approach to IP Boxes.

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To Open the Box or to Close the Box? 'Patent Box' Regimes in the EU Between R&D Incentives and Harmful Tax Practices by Daniele Fabris :: SSRN

This paper aims at assessing the foreseeable effects of the Patent Boxes and of the implementation of the Nexus Approach, as well as the compatibility of the latter with the principles of EU law.However, these new regimes may also constitute harmful tax practices, so far as multinational enterprises can exploit them for international tax planning purposes.By continuing, you agree to the use of cookies. 33 ff.Amsterdam Law Forum 11(1), 2019, pp. Available at SSRN Intellectual Property Rights.

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IP Regimes

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During the last few years, several EU Countries have enacted preferential tax regimes for the taxation of corporate income deriving from the exploitation of IP-