Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries

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Kluwer Law International B.V., 29.07.1998 - 298 Seiten
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The last half-century has seen a phenomenal increase in the volume and complexity of international business. Today's global economy allows multi-nationals to design their operations in a manner that may significantly reduce their taxes, particularly by taking advantage of tax incentives offered by many countries to attract geographically-mobile capital and activities.

Since 1962, 19 countries have enacted specific statutory regimes to counteract the perceived abuse of controlled foreign companies (CFCs) located in tax havens. In three cases to date, CFC legislation has been challenged in legal proceedings on the basis that it contravened a tax treaty. Tax Treaties and Controlled Foreign Company Legislation presents an in-depth analysis of the potential conflict between CFC legislation and tax treaties. The author also evaluates the potential conflict between the CFC legislation found in European Union countries and the EC Treaty.

This is an important resource for international tax advisers seeking to maximize clients incentive access without triggering CFC legislation. Practitioners and academics will also want to read this work to understand existing and potential conflicts in this vein.

 

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Inhalt

The legal and economic environment
1
Controlled foreign company regimes
9
International double taxation
15
Controlled foreign company regimes
23
Sweden
29
Norway
31
Tax treaties and domestic law
39
Interpretation of tax treaties by domestic courts
54
Norway
150
United Kingdom
158
Two final considerations
166
Community law affecting direct taxation
173
jurisprudence
191
jurisprudence
202
Some final remarks
215
Summary of controlled foreign company legislation
223

some final remarks
81
overview
87
The OECD Model and entity approach CFC legislation
95
The OECD Model and transaction approach CFC legislation
105
Canada
113
Denmark
122
Finland
128
Germany
134
Hungary
144
Denmark
230
Germany
236
Japan
243
New Zealand
251
Spain
258
Subject Index
281
Index of Cases
295
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