The Resource Interaction of transfer pricing rules and CFC provisions

Interaction of transfer pricing rules and CFC provisions

Label
Interaction of transfer pricing rules and CFC provisions
Title
Interaction of transfer pricing rules and CFC provisions
Creator
Subject
Language
eng
Summary
The author examines whether there is a need for both transfer pricing rules and CFC provisions, and what outcomes should be expected where these rules are applied concurrently. An analysis is provided of the structure known as the Double Irish with a Dutch Sandwich and the structure involving a so-called cash-box company in an operating lease arrangement. Moreover, the author considers (i) whether CFC rules can act as a backstop to transfer pricing rules and (ii) whether the application of these two sets of rules could lead to double taxation
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 23 (2016), no. 5 ; p. 367-377
http://library.link/vocab/creatorName
Burkadze, E
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • CFC
  • double taxation
  • double Irish
  • Dutch sandwich
Label
Interaction of transfer pricing rules and CFC provisions
Instantiates
Publication
Label
Interaction of transfer pricing rules and CFC provisions
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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