An assumption of the OECD Base Erosion and Profit Shifting initiative is that a holistic approach should be adopted. This article suggests that the reshaping of controlled foreign company rules should be coordinated with changes to corporate tax residence and anti-hybrid arrangement rules
Maisto, G., Controlled Foreign Company Legislation, Corporate Residence and Anti-Hybrid Arrangement Rules, <<BULLETIN FOR INTERNATIONAL TAXATION>>, 2014; 2014 (Giugno): 327-331 [http://hdl.handle.net/10807/66054]
Controlled Foreign Company Legislation, Corporate Residence and Anti-Hybrid Arrangement Rules
Maisto, Guglielmo
2014
Abstract
An assumption of the OECD Base Erosion and Profit Shifting initiative is that a holistic approach should be adopted. This article suggests that the reshaping of controlled foreign company rules should be coordinated with changes to corporate tax residence and anti-hybrid arrangement rulesFile in questo prodotto:
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