Taxation of Controlled Foreign Companies in Context of the OECD/G20 Project on Base Erosion and Profit Shifting as Well as the EU Proposal for the Anti-Tax Avoidance Directive - An Interim Nordic Assessment PDF Download
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Author: Peter Koerver Schmidt
Publisher:
ISBN:
Category :
Languages : en
Pages : 26
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Book Description
Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules play an important role in the ongoing efforts of the OECD/G20 and the European Commission with respect to addressing base erosion and profit shifting (BEPS). In this context, the article revisits the CFC regimes of the Nordic countries in order to assess whether these regimes are in line with the recommendations from the OECD/G20 and to determine whether Sweden, Finland, and Denmark, as EU member states, will have to make amendments if the commission's proposal for an Anti-Tax Avoidance Directive is adopted in its current form. It is concluded that the Nordic CFC regimes in many ways already are in line with the recommendations as well as the directive, but also that certain amendments have to be made.
Author: Peter Koerver Schmidt
Publisher:
ISBN:
Category :
Languages : en
Pages : 26
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Book Description
Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules play an important role in the ongoing efforts of the OECD/G20 and the European Commission with respect to addressing base erosion and profit shifting (BEPS). In this context, the article revisits the CFC regimes of the Nordic countries in order to assess whether these regimes are in line with the recommendations from the OECD/G20 and to determine whether Sweden, Finland, and Denmark, as EU member states, will have to make amendments if the commission's proposal for an Anti-Tax Avoidance Directive is adopted in its current form. It is concluded that the Nordic CFC regimes in many ways already are in line with the recommendations as well as the directive, but also that certain amendments have to be made.
Author: Nathalie Bravo
Publisher: Linde Verlag GmbH
ISBN: 3709411580
Category : Law
Languages : en
Pages : 536
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Book Description
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Author: Erik Pinetz
Publisher: Linde Verlag GmbH
ISBN: 3709408822
Category : Law
Languages : en
Pages : 454
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Book Description
Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.
Author: D.W. Blum
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
This article deals with CFC rules. The author states that the discussion of controlled foreign corporations (CFCs) in both the Final Report on Action 3 of the OECD's Base Erosion and Profit Shifting Project and the Anti-Tax Avoidance Directive (ATAD) has failed to address some high-level policy questions that are worth considering in more detail. Depending on the scope of the tax system (worldwide vs. territorial) and the means by which double taxation is avoided (credit vs. exemption), the crucial policy questions revolve around the issue as to which tax base should be protected and in which capacity (i.e. as the residence state or the source state). Moreover, the question as to whether deferral and income diversion should be curtailed as a matter of principle or only if the deferred/diverted income is low taxed in the state of residence of the CFC must be answered. On an operational level, the means by which income is included require careful assessment. Depending on whether a CFC regime pierces the CFC's corporate veil or applies a deemed dividend approach, the interaction with both the relevant distributive rules and - in case of EU Member States - the EU Fundamental Freedoms, potentially limit the scope of a CFC regime. By tracing back the underlying structural tensions inherent in domestic corporate tax laws and highlighting the policy choices that legislators face along the way to enact coherent CFC regimes that counter both tax deferral and income diversion while respecting the existing network of rules governing the allocation of taxing rights in cross-border situations, this article facilitates a principled discussion and, thus, helps to overcome the widespread BEPS fallacy of accepting the technical outcomes of the BEPS project without questioning the underlying principles.
Author: Elena G. Popkova
Publisher: Springer Nature
ISBN: 3030479455
Category : Technology & Engineering
Languages : en
Pages : 1763
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Book Description
This book presents a system view of the digital scientific and technological revolution, including its genesis and prerequisites, current trends, as well as current and potential issues and future prospects. It gathers selected research papers presented at the 12th International Scientific and Practical Conference, organized by the Institute of Scientific Communications. The conference “Artificial Intelligence: Anthropogenic Nature vs. Social Origin” took place on December 5–7, 2019 in Krasnoyarsk, Russia. The book is intended for academic researchers and independent experts studying the social and human aspects of the Fourth Industrial Revolution and the associated transition to the digital economy and Industry 4.0, as well as the creators of the legal framework for this process and its participants – entrepreneurs, managers, employees and consumers. It covers a variety of topics, including “intelligent” technologies and artificial intelligence, the digital economy, the social environment of the Fourth Industrial Revolution and its consequences for humans, the regulatory framework of the Fourth Industrial Revolution, and the “green” consequences, prospects and financing of the Fourth Industrial Revolution.
Author: Organisation for Economic Co-operation and Development
Publisher: OECD
ISBN:
Category : Business & Economics
Languages : en
Pages : 172
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Book Description
A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.
Author: Michael P. Devereux
Publisher: Oxford University Press
ISBN: 0198808062
Category : Business & Economics
Languages : en
Pages : 401
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Book Description
The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264241159
Category :
Languages : en
Pages : 75
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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 3.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264162941
Category :
Languages : en
Pages : 82
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Book Description
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Author: Reuven S. Avi-Yonah
Publisher: Cambridge University Press
ISBN: 9780521852838
Category : Law
Languages : en
Pages : 224
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Book Description
This book explains how the tax rules of the various countries in the world interact with one another to form an international tax regime: a set of principles embodied in both domestic legislation and treaties that significantly limits the ability of countries to choose any tax rules they please. The growth of this international tax regime is an important part of the phenomenon of globalization, and the book delves into how tax revenues are divided among different countries. It also explains how U.S. tax rules in particular apply to cross-border transactions and how they embody the norms of the international tax regime.
