The Revenue Authorities of 17 OECD member countries, including Ireland and the UK, have collaborated on a study to summarise the tax treatment of Corporation tax losses in their respective jurisdictions.

The report, entitled “Corporate Loss Utilisation through Aggressive Tax Planning”, describes itself as –

• Identifying the size of corporate tax losses and the policy issues related to their tax treatment,
• Identifying risk areas, from the perspective of revenue authorities, in relation to the use of losses for tax purposes – corporate reorganisations, financial instruments and non-arm's length transfer pricing,
• Summarising aggressive tax planning schemes encountered by revenue bodies in participating countries.

Perhaps the most useful chapter, from the perspective of practising tax professionals, is the summary and overview of the loss rules in the 17 participating countries.

That such a report is compiled at all is symptomatic of concerns on the impact to tax revenues of corporate losses arising from the downturn.

The report is available for purchase from the OECD.