How Controlled Foreign Corporation Rules Look around the World: Netherlands

The Netherlands did not have a CFC regime until it was made mandatory by the European Commission Anti-tax services Avoidance Directive (ATAD). The debut of CFC rules in the Dutch tax services system was in January 2019. The Dutch system includes a full participation...

How Controlled Foreign Corporation Rules Look Around the World: Japan

The second post of this series explains how the Controlled Foreign Corporation (CFC) rules work in Japan. CFC rules were incorporated by Japanese legislation in 1978. In 2017, Japan amended its CFC legislation to adjust the rules with some of the recommendations...

The Challenges of Consensus in the Digital Economy on the International Tax Treaty System

The OECD has already released the program of work to develop a consensus solution to the tax services Challenges Arising from the Digitalization of the Economy. Right now, the OECD is working on the design of the possible solutions that can be suitable for giving new...

How Controlled Foreign Corporation Rules Look Around the World

This post is the first in a series about Controlled Foreign Corporation (CFC) rules, which were created to provide countries a tool to tax services part of the income that foreign subsidiaries earn abroad. Multinational corporations do business in different countries...