Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development and published by OECD. This book was released on 1996 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Tax Treaties and Controlled Foreign Company Legislation Pushing the Boundaries written by Daniel Sandler and published by Kluwer Law International B.V.. This book was released on 1998-07-29 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 423 pages. 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.

Download or read book Controlled Foreign Company Legislation written by Georg Kofler (Professor of tax law at the University of Linz.) and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Controlled Foreign Companies written by Lee Burns and published by . This book was released on 1992 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

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 and published by OECD Publishing. This book was released on 2015-10-05 with total page 75 pages. 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.

Download or read book CFC Legislation Tax Treaties and EC Law written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2004-01-01 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book The Taxation of Controlled Foreign Corporations written by John Prebble and published by . This book was released on 1987 with total page 86 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the taxation of controlled foreign corporation in New Zealand with reference to other country's approach.

Download or read book New Controlled Foreign Company Legislation in Taiwan written by Yishian Lin and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Pushing the Boundaries written by Daniel Sandler and published by . This book was released on 1994 with total page 152 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book The Controlled Foreign Companies Legislation written by Institute of Chartered Accountants in England and Wales and published by . This book was released on 1996 with total page 9 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Controlled Foreign Companies written by David Ross and published by . This book was released on 1998 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Designing Effective Controlled Foreign Company Rules Action 3 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015-10-12 with total page 54 pages. 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.

Download or read book The Evolution of Controlled Foreign Corporation Rules and Beyond written by B.J. Arnold and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article traces the evolution of controlled foreign corporation (CFC) rules, including their compatibility with treaty provisions. It argues that CFC rules would be preferable to the Inclusive Framework proposal on the OECD/G20 Base Erosion and Profit Shifting Project (Pillar Two) for a uniform minimum tax on all CFC income.

Download or read book The Controlled Foreign Companies Excluded Territories Regulations 2012 written by Great Britain and published by . This book was released on 2012-12-06 with total page 8 pages. Available in PDF, EPUB and Kindle. Book excerpt: Enabling power: Taxation (International and Other Provisions) Act 2010, s. 371KB (2) (3). Issued: 06.12.2012. Made: 03.12.2012. Laid: 05.12.2012. Coming into force: 01.01.2013. Effect: 2010 c. 8 modified. Territorial extent & classification: E/W/S/NI. General

Download or read book Controlled Foreign Company Legislation written by Georg Kofler (Professor of tax law at the University of Linz.) and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Controlled Foreign Companies written by Eric Tomsett and published by . This book was released on 1984 with total page 69 pages. Available in PDF, EPUB and Kindle. Book excerpt: