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Interest Barriers under the OECD's BEPS Action Plan 4
INTRO
Intro (2:24)
COURSE AGENDA
Course Agenda (1:11)
BEPS ACTION PLAN 4 : OVERALL OBJECTIVE
BEPS Action Plan 4 - Overall Objective (6:21)
OVERVIEW OF BEST PRACTICE APPROACH
Overview of best practice approach (6:31)
TARGETS OF BEST PRACTICE APPROACH
Targets of best practice approach (2:48)
DEFINITION OF INTEREST
Definition of Interest (4:03)
FIXED RATIO RULE
Fixed ratio rule (2:34)
Fixed ratio rule - Illustration 1 Question with Answer (2:09)
Fixed ratio rule - Illustration 2 Question (2:39)
Fixed ratio rule - Illustration 2 Answer (2:01)
FIXED RATIO RULE - EBITDA
Fixed ratio rule - EBITDA (2:44)
Fixed ratio rule - EBITDA - Illustration 1 Question with Answer (4:23)
Fixed ratio rule - EBITDA - Illustration 2 Question (7:01)
Fixed ratio rule - EBITDA - Illustration 2 Answer (2:36)
Fixed ratio rule - EBITDA - Illustration 3 Question (1:10)
Fixed ratio rule - EBITDA - Illustration 3 Answer (20:19)
GROUP RATIO RULE
Group ratio rule (7:01)
Group ratio rule - Illustration 1 Question with answer (5:53)
Group ratio rule - Illustration 2 Question (3:25)
Group ratio rule - Illustration 2 Answer (4:47)
GROUP RATIO RULE - NET THIRD PARTY INTEREST
Group ratio rule - Net third party interest (6:18)
GROUP RATIO RULES - UPLIFT - ILLUSTRATION 1
Group ratio rule - Uplift - Illustration 1 Question with Answer (4:28)
GROUP RATIO RULE - GROUP EBITDA
Group ratio rule - Group EBITDA (12:45)
GROUP RATIO RULE - WHAT IS A GROUP?
Group ratio rule - What is a group? (1:50)
CARRY FORWARD AND CARRY BACK OF INTEREST
Carry forward and carry back of interest (5:21)
TARGETED RULES
Targeted rules (5:11)
Outro (0:53)
Carry forward and carry back of interest
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