Reference : The Controlled Foreign Company Regime
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Law, criminology & political science : Tax law
Law, criminology & political science : European & international law
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The Controlled Foreign Company Regime
Haslehner, Werner mailto [University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit >]
The EU Common Consolidated Corporate Tax Base - Critical Analysis
Weber, Dennis
Van de Streek, Jan
Kluwer Law International
Eucotax Series on European Taxation - Volume 58
Alphen aan den Rijn
The Netherlands
[en] Controlled Foreign Company ; CFC ; EU Tax Harmonisation ; EU corporate taxation ; BEPS ; ATAD
[en] The Controlled Foreign Company (CFC) regime proposed by the Commission as part of the newly launched Common Corporate Tax Base (CCTB) project reflects the perceived need to strengthen the Union’s anti-tax avoidance measures, and specifically to discourage profit shifting to low-tax jurisdictions. The proposed rule largely reflects previous work done by the OECD as part of the BEPS project and the EU implementation measures in the Anti-Tax Avoidance Directive (ATAD), but it deviates from both in a number of its details. This contribution aims to provide a first technical analysis of the provision to reveal its scope, its mechanism, and apparent shortcomings. It furthermore tries to imbed it in its context of existing primary and secondary EU law.
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