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Base Erosion and Profit Shifting – Wikipedia

OECD, Base Erosion & Profit Shifting, Multinationals. Political leaders, media outlets, and civil society around the world have expressed growing concern about tax planning by multinational enterprises (MNEs) that makes use of gaps in the interaction of different tax systems This issue is related to Action 3 on designing effective controlled foreign company rules (CFC). These rules respond to the risk that taxpayers with a controlling interest in a foreign subsidiary can strip the base of their country of residence and, in some cases, other countries by shifting income into a CFC. BEPS Action 3, through adopting the combined de minimus approach and low effective tax rate rules, and should be maintained. It is recommended, 12 ‘The initial CFC legislation in 2001 referred to “controlled foreign entities” (CFEs) as opposed to Following the release of the final paper on Action 3 of the OECD BEPS agenda, which concerns CFCs. Now CFCs or Controlled Foreign Company rules aim to prevent the avoidance of tax through shifting profits to low tax foreign subsidiaries. April30 2015 BEPS Action 3: CFC Rules Page 3 appropriate to provide a refund of CFC taxes paid equal to the amount of the withholding tax if the dividend was paid out of profits that were subject to CFC tax . .

16. Action 6 Confederation of Swedish Enterprise – Comments on the OECD Public Discussion Draft entitled: “BEPS ACTION 3: Strengthening CFC Rules” 03 April 2015 Confederation of Swedish Enterprise – Comments on the OECD Public Discussion Draft entitled: “BEPS ACTION 3: Strengthening CFC Rules” Titel: OECD Designing Effective Controlled Foreign Company Rules – Action 3 - 2015 Final Report. Utgivningsår: 2015. Omfång: 69 sid.

BEPS-åtgärdspunkterna Skatteverket

• Scope: Action Item 3 (Strengthen CFC Rules). BEPS MONITORING GROUP.

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Action 11: Measuring and Monitoring BEPS : Action 12: Mandatory Disclosure Rules (EN / FR / ES / KOR) ‌ Action 13: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting (EN / FR / ES / DEU) Action 14: Making Dispute Resolution Mechanisms More Effective (EN / FR / ES / KOR) ‌ BEPS Action 3 Strengthen CFC rules Potential policy change Rules in many countries do not always counter BEPS comprehensively. Develop recommendations regarding design of domestic CFC rules.

General comments As a general rule, we agree with the comment in paragraph 85 of the discussion draft that CFC rules 2015-10-05 Europe: BEPS Action 13 Implementation Belgium CbCR/MF/LF Iceland CbCR Finland CbCR/MF/LF Bulgaria Greece Norway CbCR MF/LF Denmark CbCR/MF/LF Germany CbCR/MF/LF Switzerland CbCR MF/LF Luxembourg CbCR Netherlands CbCR/MF/LF U.K. CbCR/MF/LF Isle of Man CbCR MF/LF Ireland Guernsey CbCR CbCR Jersey CbCR France CbCR/MF/LF Portugal CbCR Gibraltar BEPS MONITORING GROUP Comments on BEPS Action 3: Strengthening the Rules on Controlled Foreign Corporations (CFCs) This report is published by the BEPS Monitoring Group (BMG). The BMG is a group of experts on various aspects of international tax, set up by a number of civil society Taxation is at the core of countries' sovereignty, but in recent years, multinational companies have avoided taxation in their home countries by pushing activities abroad to low or no tax jurisdictions.
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Jämförbarhetsanalys. En skriftlig dokumentation som beskriver vilka med BEPS-projektet utformat 13 s.k. ”action points”.

BEPS Discussion Draft: Action 3: Strengthening CFC rules PricewaterhouseCoopers LLP (PwC) welcomes the opportunity to comment on the OECD’s Public Discussion Draft on Action 3: Strengthening CFC rules. In light of the complexity of the subject matter and the diversity of existing approaches adopted by tional business environment, and many of them have design features that do not tackle BEPS effec-tively. In response to the challenges faced by existing CFC rules, the Action Plan on Base Erosion and Prof-it Shifting (BEPS Action Plan, OECD, 2013) called for the development of recommendations regard-ing the design of CFC rules. The recent BEPS discussion drafts, Action 3 re: CFC rules and Action 12 re: Aggressive tax planning arrangements, are of paramount importance for all MNE’s and tax administrations.
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Confederation of Swedish Enterprise – Comments on the

These rules respond to the risk that taxpayers with a controlling interest in a foreign subsidiary BEPS Action 3 “Designing effective controlled foreign company rules” aims to develop recommendations regarding the design and strengthening of controlled foreign company (CFC) rules, to address concerns over the possibility of creating affiliated non-resident taxpayers and routing income of a resident enterprise through the non-resident affiliate to reduce or avoid taxation. BEPS Actions Developed in the context of the OECD/G20 BEPS Project, the 15 actions set out below equip governments with domestic and international rules and instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created. Action 11: Measuring and Monitoring BEPS : Action 12: Mandatory Disclosure Rules (EN / FR / ES / KOR) ‌ Action 13: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting (EN / FR / ES / DEU) Action 14: Making Dispute Resolution Mechanisms More Effective (EN / FR / ES / KOR) ‌ BEPS Action 3 Strengthen CFC rules Potential policy change Rules in many countries do not always counter BEPS comprehensively.

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Substance in tax structuring: Webinar Evenemang DLA

1 KOM(2012) 722 lopullinen.

BEPS ACTION 4 - Uppsatser.se

These rules respond to the risk that taxpayers with a controlling interest in a foreign subsidiary can strip the base of their country of residence and, in some cases, other countries by shifting income into a CFC. BEPS Action 3, through adopting the combined de minimus approach and low effective tax rate rules, and should be maintained. It is recommended, 12 ‘The initial CFC legislation in 2001 referred to “controlled foreign entities” (CFEs) as opposed to Following the release of the final paper on Action 3 of the OECD BEPS agenda, which concerns CFCs. Now CFCs or Controlled Foreign Company rules aim to prevent the avoidance of tax through shifting profits to low tax foreign subsidiaries. April30 2015 BEPS Action 3: CFC Rules Page 3 appropriate to provide a refund of CFC taxes paid equal to the amount of the withholding tax if the dividend was paid out of profits that were subject to CFC tax .

Local File OECD BEPS Action Plan: Moving from talk to action in the Americas OECD BEPS Action Plan: Moving from talk to action in the Americas 3 2017 KPMG International Cooperative (KPMG International). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.