| Description |
xxv, 298 pages ; 25 cm |
| Series |
CIOT ; 2 |
|
Chartered Institute of Taxation (Series) ; 2
|
| Contents |
Ch. 1. The legal and economic environment -- Ch. 2. Controlled foreign company regimes -- Ch. 3. Tax treaties and domestic law -- Ch. 4. OECD Model Treaty and CFC legislation -- Ch. 5. Treaty practice of states following enactment of CFC legislation -- Ch. 6. CFC legislation and European Union Treaty provisions -- Ch. 7. CFC legislation and tax treaties: jurisprudence -- Ch. 8. Conclusions |
| Summary |
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 |
| Notes |
On t.p.: The Chartered Institute of Taxation |
|
Previous ed.: published as Pushing the boundaries. London : The Institute of Taxation in collaboration with The Institute for Fiscal Studies, 1994 |
| Bibliography |
Includes bibliographical references (pages 269-278) and indexes |
| Subject |
Controlled foreign corporations -- Taxation.
|
|
Corporations, Foreign -- Taxation -- Law and legislation.
|
|
Double taxation.
|
| Author |
Sandler, Daniel.
Pushing the boundaries
|
|
Chartered Institute of Taxation.
|
|
Confédération fiscale européenne.
|
| LC no. |
98020952 |
| ISBN |
9041196536 |
|
