<abstract xmlns="http://www.w3.org/1999/xhtml"><p>Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules play an important role in the ongoing efforts of the OECD/G20 and the European Commission with respect to addressing base erosion and profit shifting (BEPS). In this context, the article revisits the CFC regimes of the Nordic countries in order to assess whether these regimes are in line with the recommendations from the OECD/G20 and to determine whether Sweden, Finland, and Denmark, as EU member states, will have to make amendments if the commission’s proposal for an Anti-Tax Avoidance Directive is adopted in its current form. It is concluded that the Nordic CFC regimes in many ways already are in line with the recommendations as well as the directive, but also that certain amendments have to be made.</p></abstract>

Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules play an important role in the ongoing efforts of the OECD/G20 and the European Commission with respect to addressing base erosion and profit shifting (BEPS). In this context, the article revisits the CFC regimes of the Nordic countries in order to assess whether these regimes are in line with the recommendations from the OECD/G20 and to determine whether Sweden, Finland, and Denmark, as EU member states, will have to make amendments if the commission’s proposal for an Anti-Tax Avoidance Directive is adopted in its current form. It is concluded that the Nordic CFC regimes in many ways already are in line with the recommendations as well as the directive, but also that certain amendments have to be made.

Taxation of Controlled Foreign Companies in Context of the OECD/G20 Project on Base Erosion and Profit Shifting as well as the EU Proposal for the Anti-Tax Avoidance Directive – An Interim Nordic Assessment

Assistant Professor, Copenhagen Business School and Technical Advisor, CORIT Advisory P/S,

Nordic Tax Journal

This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 3.0 License.

Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules play an important role in the ongoing efforts of the...

Taxation of Controlled Foreign Companies in Context of the OECD/G20 Project on Base Erosion and Profit Shifting as well as the EU Proposal for the Anti-Tax Avoidance Directive – An Interim Nordic Assessment

Article Category: Article

Publié en ligne: 10 déc. 2016

Pages: 87 - 112

Reçu: 27 avr. 2016

Accepté: 26 mai 2016

DOI: https://doi.org/10.1515/ntaxj-2016-0005

Mots clés
CFC legislation, BEPS, Anti-Tax Avoidance Directive, comparative law, EU law, tax treaties

© 2016 P. K. Schmidt

This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 3.0 License.

Taxation of Controlled Foreign Companies in Context of the OECD/G20 Project on Base Erosion and Profit Shifting as well as the EU Proposal for the Anti-Tax Avoidance Directive – An Interim Nordic Assessment

Article Category: Article

Publié en ligne: 10 déc. 2016

Pages: 87 - 112

Reçu: 27 avr. 2016

Accepté: 26 mai 2016

DOI: https://doi.org/10.1515/ntaxj-2016-0005

Mots clésCFC legislation, BEPS, Anti-Tax Avoidance Directive, comparative law, EU law, tax treaties

© 2016 P. K. Schmidt

This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 3.0 License.

Mots clés
CFC legislation, BEPS, Anti-Tax Avoidance Directive, comparative law, EU law, tax treaties