Add to ORKGIn this article the proposal Concerning “Best Practices” and Principles for a Common Legislation on CFC Compatibility with Community Law are set forth. The “best practice” purpose of CFC legislation should be that of avoiding the abuse related to the use of legal entities in the international environment to achieve a tax deferral goal, the term “abuse” meaning the use of “wholly artificial arrangements” as indicated by the European Court of Justice (ECJ) in Cadbury Schweppes, paras 64 to 68, Case C-196/04, decision dated 12 September 2006
Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules...
The author considers the minimum level of substance EU Member States may require in light of the fre...
peer reviewedThe Controlled Foreign Company (CFC) regime proposed by the Commission as part of the n...
In this article the proposal Concerning \u201cBest Practices\u201d and Principles for a Common Legis...
In this article the proposal Concerning “Best Practices” and Principles for a Common Legislation on ...
In this article the proposal Concerning “Best Practices” and Principles for a Common Legislation on ...
Most states within the EU have some kind of CFC-legislation that allows the state in question to tax...
Although direct taxation falls under the sovereignty of each individual Member State, that sovereign...
This article deals with the problems of taxation of controlled foreign companies (hereinafter: CFC) ...
CFC legislation has become an instrument to protect national tax bases and minimize the abusive effe...
The purpose of the paper is to investigate both the Swedish position and the position of ECJ regardi...
During the last half-century there has been an increase in the volume and complexity of internationa...
The CCCTB architecture seems to address the major tax design issues relating to foreign business pro...
Controlled foreign corporation rules are a fundamental piece of the international tax regime. They p...
This thesis on international tax law deals with the topic Controlled Foreign Corporation (CFC) legis...
Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules...
The author considers the minimum level of substance EU Member States may require in light of the fre...
peer reviewedThe Controlled Foreign Company (CFC) regime proposed by the Commission as part of the n...
In this article the proposal Concerning \u201cBest Practices\u201d and Principles for a Common Legis...
In this article the proposal Concerning “Best Practices” and Principles for a Common Legislation on ...
In this article the proposal Concerning “Best Practices” and Principles for a Common Legislation on ...
Most states within the EU have some kind of CFC-legislation that allows the state in question to tax...
Although direct taxation falls under the sovereignty of each individual Member State, that sovereign...
This article deals with the problems of taxation of controlled foreign companies (hereinafter: CFC) ...
CFC legislation has become an instrument to protect national tax bases and minimize the abusive effe...
The purpose of the paper is to investigate both the Swedish position and the position of ECJ regardi...
During the last half-century there has been an increase in the volume and complexity of internationa...
The CCCTB architecture seems to address the major tax design issues relating to foreign business pro...
Controlled foreign corporation rules are a fundamental piece of the international tax regime. They p...
This thesis on international tax law deals with the topic Controlled Foreign Corporation (CFC) legis...
Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules...
The author considers the minimum level of substance EU Member States may require in light of the fre...
peer reviewedThe Controlled Foreign Company (CFC) regime proposed by the Commission as part of the n...