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On 3 April 2015 the OECD released a discussion draft which deals with action 3 (Strengthening CFC Rules) of the Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan).

In July 2013, the BEPS Action Plan directed the OECD to commence work on 15 actions designed to ensure the coherence of corporate income taxation at the international level. The first seven of these actions were presented to G20 Leaders at the Brisbane Summit in November 2014.

Action 3 of the BEPS Action Plan focuses on developing recommendations for the design of controlled foreign company (CFC) rules to combat base erosion and profit shifting.

This discussion draft considers all the constituent elements of CFC rules and breaks them down into the “building blocks” that are necessary for effective CFC rules. The discussion draft also identifies specific questions where input is required in order to advance the work on CFC rules.

The Action Plan calls for this work to be completed by September 2015. The Committee on Fiscal Affairs (CFA) invites interested parties to send comments on this discussion draft. Comments should be submitted by 1 May 2015.

Details, and the full text of the discussion draft, are available here.

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