The Resource The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it
The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it
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The item The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it 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 The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it 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 deals with the problem of double economic taxation triggered by CFC rules under tax treaties based on the Model Tax Convention of the OECD. In that respect, the author first provides and analyses several arguments speaking in favour of the thesis that OECD tax treaties target double economic taxation triggered by an application of the CFC rules and the treaties therefore require Contracting States applying CFC rules to avoid said double economic taxation. Subsequently, the way in which the double economic taxation should be avoided by Contracting States is discussed. Finally, the author concludes that the need to avoid double economic taxation triggered by the application of CFC rules under OECD tax treaties is internationally recognized and respected and that the appropriate way to achieve it is to credit taxes paid by the CFC if this company does not constitute a PE of its participants, or, exempt its income from taxation if it constitutes a PE of its participants and the exemption method applies to its income
- Language
- eng
- Label
- The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it
- Title
- The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it
- Language
- eng
- Summary
- This article deals with the problem of double economic taxation triggered by CFC rules under tax treaties based on the Model Tax Convention of the OECD. In that respect, the author first provides and analyses several arguments speaking in favour of the thesis that OECD tax treaties target double economic taxation triggered by an application of the CFC rules and the treaties therefore require Contracting States applying CFC rules to avoid said double economic taxation. Subsequently, the way in which the double economic taxation should be avoided by Contracting States is discussed. Finally, the author concludes that the need to avoid double economic taxation triggered by the application of CFC rules under OECD tax treaties is internationally recognized and respected and that the appropriate way to achieve it is to credit taxes paid by the CFC if this company does not constitute a PE of its participants, or, exempt its income from taxation if it constitutes a PE of its participants and the exemption method applies to its income
- Citation source
- In: Intertax. - Alphen aan den Rijn. - Vol. 43 (2015),
- http://library.link/vocab/creatorName
- Kuźniacki, B
- Geographic coverage
- International
- Language note
- English
- http://library.link/vocab/subjectName
-
- OECD
- OECD Model
- CFC
- tax treaty
- avoidance of double taxation
- PE
- credit method
- exemption method
- Label
- The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it
- Label
- The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it
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<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/The-need-to-avoid-double-economic-taxation/VdI5FTq-Rwc/" 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/The-need-to-avoid-double-economic-taxation/VdI5FTq-Rwc/">The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it</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>
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<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/The-need-to-avoid-double-economic-taxation/VdI5FTq-Rwc/" 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/The-need-to-avoid-double-economic-taxation/VdI5FTq-Rwc/">The need to avoid double economic taxation triggered by CFC rules under tax treaties, and the way to achieve it</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>
