Tax Treaties and Controlled Foreign Company Legislation —— Pushing the Boundaries

----- 英国皇家税务协会：税务协定与受控外国公司立法

ISBN: 9789041196538 出版年：1998 页码：326 Sandler, Daniel Kluwer Law International

The last half-century has seen a phenomenal increase in the volume and complexity of international business. Today's 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, nineteen 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 book is the most comprehensive work available on these subjects. It is essential reading for international tax advisers.