The Resource Discriminatory tax treatment of CFC's losses towards losses of partnerships, economic double taxation, exchange of tax information and future developments of the Norwegian CFC rules

Discriminatory tax treatment of CFC's losses towards losses of partnerships, economic double taxation, exchange of tax information and future developments of the Norwegian CFC rules

Label
Discriminatory tax treatment of CFC's losses towards losses of partnerships, economic double taxation, exchange of tax information and future developments of the Norwegian CFC rules
Title
Discriminatory tax treatment of CFC's losses towards losses of partnerships, economic double taxation, exchange of tax information and future developments of the Norwegian CFC rules
Creator
Subject
Language
eng
Summary
This article focuses on selected issues related to the compatibility of the Norwegian controlled foreign company (CFC) rules with the European Economic Area (EEA) law: namely discriminatory tax treatment of CFC's losses and economic double taxation. It also analyses whether the restrictions of fundamental freedoms may be justified by the lack of the applicability of a legal instrument for exchanging tax information with tax authorities of a CFC's resident state. Finally, the author provides conclusions and his thoughts on future developments regaring the CFC rules - Action plan on BEPS and the necessity for introducing the new exemption from their application, i.e. "genuine economic activities exemption"
Citation source
In: Skatterett. - Oslo. - (2014),
http://library.link/vocab/creatorName
Kuźniacki, B
Geographic coverage
Europe
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • losses
  • double taxation
  • discrimination
  • fundamental freedoms
  • justification
  • EEA
  • tax treaty
  • exchange of information
  • BEPS Project (OECD)
Label
Discriminatory tax treatment of CFC's losses towards losses of partnerships, economic double taxation, exchange of tax information and future developments of the Norwegian CFC rules
Instantiates
Publication
Label
Discriminatory tax treatment of CFC's losses towards losses of partnerships, economic double taxation, exchange of tax information and future developments of the Norwegian CFC rules
Publication

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