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Vol 21 No 9 Sept/Oct 2016

Book of the Month

Cover of Goode on Commercial Law

Goode on Commercial Law

Edited by: Ewan McKendrick
Price: £170.00

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Tax Treaties and Controlled Foreign Company Legislation: Pushing the Boundaries 2nd ed

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ISBN13: 9789041196538
ISBN: 9041196536
Published: October 1998
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £165.00

This is a Print On Demand Title.
The publisher will print a copy to fulfill your order. Books can take between 1 to 3 weeks. Looseleaf titles between 1 to 2 weeks.

The last half of the 20th-century has seen a phenomenal increase in the volume and complexity of international business. Global economy allows multinationals 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 located in tax havens. In three cases to date, controlled foreign company (CFC) legislation has been challenged in legal proceedings on the basis that it contravened a tax treaty. The author 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 comprehensive work should be of interest to international tax advisers.

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The legal and economic environment; controlled foreign company regimes; tax treaties and domestic law; OECD model treaty and CFC legislation; treaty practice of states following enactment of CFC legislation; CFC legislation and European Union treaty provisions; CFC legislation and tax treaties - jurisprudence. Appendix: summary of controlled foreign company legislation.