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
Categoria dell'articolo: Article
Pubblicato online: 10 dic 2016
Pagine: 87 - 112
Ricevuto: 27 apr 2016
Accettato: 26 mag 2016
DOI: https://doi.org/10.1515/ntaxj-2016-0005
Parole chiave
© 2016 P. K. Schmidt
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 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.