Shifting of profits from and to foreign subsidiaries

Resource Information

The work Shifting of profits from and to foreign subsidiaries represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Shifting of profits from and to foreign subsidiaries

Creator

• Waardenburg, D.A. van

Subject

• CFC
• arm's length principle
• profit shifting

Language

eng

Summary

International operations create the problem of allocation of profits between French and foreign operations and it is for this purpose that Article 57 of the French General Tax Code has been included in French tax legislation. This article essentially provides for a computation of taxable income on an arm's-length basis. The French tax administration has issued a ruling which implements Article 57, especially with respect to shifting of profits from and to French enterprises which control or are controlled by foreign enterprises. The author discusses and comments on the new ruling

Citation source

In: European taxation. - Amsterdam. - Vol. 13 (1973),

Geographic coverage

European Union

Language note

English