The OECD has provided its latest consultation inviting comments re: CFC rules, using 7 building blocks for discussion.
- Definition of a CFC
- Threshold requirements
- Definition of control
- Definition of CFC income
- Rules for computing income
- Rules for attributing income
- Rules to prevent or eliminate double taxation
A link to the consultation is provided for reference:
Click to access discussion-draft-beps-action-3-strengthening-CFC-rules.pdf
As CFC rules are the foundation underlying a country’s right of taxation, while fiscal pressures are forcing administrations to increase their fisc creatively and aggressively, this consultation indicates the long-term strategies for CFC taxation. Â Accordingly, MNE’s and other interested parties should review and provide comments accordingly.
Strategizing Multinational Tax Risks 
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