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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: 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: Nathalie Bravo
Publisher: Linde Verlag GmbH
ISBN: 3709411599
Category : Law
Languages : de
Pages : 423
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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: Georg Kofler (Professor of tax law at the University of Linz.)
Publisher:
ISBN: 9789087226466
Category :
Languages : en
Pages :
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Book Description
Author: Daniel Sandler
Publisher: Kluwer Law International B.V.
ISBN: 9041196536
Category : Business & Economics
Languages : en
Pages : 326
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Book Description
In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
Author: Lee Burns
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 304
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Book Description
This book is an explanation of Australia's CFC rules. It places the legislation in context, provides a framework for analysing problems and describes the new regime in detail.
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: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 9041122842
Category : Law
Languages : en
Pages : 658
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Book Description
Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.
Author: John Prebble
Publisher:
ISBN:
Category : Corporations, Foreign
Languages : en
Pages : 86
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Book Description
Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.
Author: Georg Kofler (Professor of tax law at the University of Linz.)
Publisher:
ISBN: 9789087226459
Category :
Languages : en
Pages :
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Book Description
Author: Yishian Lin
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In this article, the author discusses the controlled foreign company (CFC) legislation recently introduced in Taiwan. The article gives an overview of the main features of the legislation and the Ministry of Finance's implementation rules. It also addresses double tax relief issues in the context of tiered foreign companies, and the different tax treatment of interests in companies in Mainland China and those in other foreign jurisdictions. The author canvasses the impact on the new rules of the simultaneously introduced place of effective management law, and exchange of information agreements.
