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Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report

2015-10-12 Controlled foreign corporations
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Release : 2015-10-12
Genre : Controlled foreign corporations
Kind : eBook
Book Rating : 145/5 ( reviews)

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Book Synopsis Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report by : OCDE,

Download or read book Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report written by OCDE,. This book was released on 2015-10-12. Available in PDF, EPUB and Kindle. Book excerpt: This report sets out recommendations in the form of building blocks for effective CFC rules. The recommendations are designed to ensure that jurisdictions that choose to implement them, have rules that effectively prevent taxpayers from shifting income into foreign subsidiaries. The report sets out the following six building blocks for the design of effective CFC rules: (1) definition of a CFC, (2) CFC exemptions and threshold requirements, (3) definition of income, (4) computation of income, (5) attribution of income, and (6) prevention and elimination of double taxation. Because each country prioritises policy objectives differently, the recommendations provide flexibility to implement CFC rules that combat BEPS in a manner consistent with the policy objectives of the overall tax system and the international legal obligations of the country concerned.

OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report

2015-10-05
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Release : 2015-10-05
Genre :
Kind : eBook
Book Rating : 159/5 ( reviews)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report written by OECD. This book was released on 2015-10-05. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Designing effective controlled foreign company rules, action 3-2015 final report

2015
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Release : 2015
Genre :
Kind : eBook
Book Rating : /5 ( reviews)

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Book Synopsis Designing effective controlled foreign company rules, action 3-2015 final report by :

Download or read book Designing effective controlled foreign company rules, action 3-2015 final report written by . This book was released on 2015. Available in PDF, EPUB and Kindle. Book excerpt:

Concept and Implementation of CFC Legislation

2021-09-21 Law
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Release : 2021-09-21
Genre : Law
Kind : eBook
Book Rating : 599/5 ( reviews)

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Book Synopsis Concept and Implementation of CFC Legislation by : Nathalie Bravo

Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo. This book was released on 2021-09-21. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Concept and Implementation of CFC Legislation

2021-09-21 Law
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Author :
Release : 2021-09-21
Genre : Law
Kind : eBook
Book Rating : 580/5 ( reviews)

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Book Synopsis Concept and Implementation of CFC Legislation by : Nathalie Bravo

Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo. This book was released on 2021-09-21. Available in PDF, EPUB and Kindle. Book excerpt: 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.

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