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
Resource Information
The item 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 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item 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 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- 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"
- Language
- eng
- 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
- 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
- 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
Embed
Settings
Select options that apply then copy and paste the RDF/HTML data fragment to include in your application
Embed this data in a secure (HTTPS) page:
Layout options:
Include data citation:
<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Discriminatory-tax-treatment-of-CFCs-losses/ZwCUi5S9sQk/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Discriminatory-tax-treatment-of-CFCs-losses/ZwCUi5S9sQk/">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</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
Note: Adjust the width and height settings defined in the RDF/HTML code fragment to best match your requirements
Preview
Cite Data - Experimental
Data Citation of the Item 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
Copy and paste the following RDF/HTML data fragment to cite this resource
<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Discriminatory-tax-treatment-of-CFCs-losses/ZwCUi5S9sQk/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Discriminatory-tax-treatment-of-CFCs-losses/ZwCUi5S9sQk/">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</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
