The Resource The role of CFC rules in the BEPS initiative and in the EU

The role of CFC rules in the BEPS initiative and in the EU

Label
The role of CFC rules in the BEPS initiative and in the EU
Title
The role of CFC rules in the BEPS initiative and in the EU
Creator
Subject
Language
eng
Summary
This article discusses the purpose of the controlled foreign companies (CFC) rules in the base erosion and profit shifting (BEPS) initiative, how they contribute to the holistic approach and the meaning of co-ordination among the BEPS actions. It also discusses the compatibility of CFC rules with EU law in the EU BEPS context: whether EU law only sets limits to CFC rules adopted by EU member states and applied to other EU member states or if EU law also limits CFC rules adopted by EU member states towards non-EU jurisdictions. Whereas in the BEPS initiative CFC rules are an element of tension between source and residence states, in the EU, member states face serious difficulties in adopting effective CFC rules because of the so far too narrow interpretation of avoidance (that is, artificiality) by the Court of Justice of the European Union
Citation source
In: British tax review. - London. - (2015),
Language note
English
Label
The role of CFC rules in the BEPS initiative and in the EU
Instantiates
Publication
Label
The role of CFC rules in the BEPS initiative and in the EU
Publication

Library Locations

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