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Controlled Foreign Corporation (CFC) Rules

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Anti-Avoidance Policies in a Pillar Two World including CFC rules and Base erosion and Profit Shifting Pillar Two policies

Anti-Avoidance Policies in a Pillar Two World

The global minimum tax agreement known as Pillar Two is intended to curb profit shifting. However, OECD countries already have a variety of mechanisms in place that seek to prevent base erosion and profit shifting by multinational corporations.

40 min read
Risks to the U.S. Tax Base from Pillar Two

Risks to the U.S. Tax Base from Pillar Two

A growing international tax agreement known as Pillar Two presents two new threats to the U.S. tax base: potential lost revenue and limitations on Congress’s ability to set its own tax policy.

39 min read

Weeding the Garden of International Tax

Simplifying international tax rules will not solve all the challenges that stand in the way of healthy cross-border investment, but eliminating unnecessary provisions would be a positive pivot relative to the trajectory of recent years. It’s high time that policymakers stopped pursuing ever more complex rules and started the hard work of simplification.

6 min read
Carbon Border Adjustment Mechanism EU CBAM carbon price carbon tariffs US global minimum tax US tax incentives Build Back Better tax rate on gilti Global Intangible Low Tax Income (GILTI) Global intangible low-taxed income US cross-border tax reform and GILTI Global Intangible Low Tax Income. Foreign tax credits

JCT Analyzes Federal Revenue Effects of Pillar Two

The JCT analysis raises some useful questions for the U.S. domestic debate over Pillar Two. The Treasury Department should examine its support for an agreement that will reduce its own revenue intake. But it is also worth noting that the principal mechanism for the revenue reduction—the foreign tax credit—is a policy already baked into U.S. law, including the Republican-enacted global minimum tax from 2017. The OECD deal merely takes advantage of this longstanding feature.

6 min read
Analysis of the Cost-of-Living Refund Act of 2019 Sherrod Brown Ro Khanna, EITC expansion low-income credit

How Heavily Taxed Are U.S. Multinationals?

In general, the effective tax rates on the foreign profits of U.S. multinationals are not that low relative to the U.S. tax rate, contrary to popular rhetoric.

7 min read
Controlled Foreign Corporation CFC Rules in Europe base erosion and profit shifting 2021

CFC Rules in Europe

To prevent businesses from minimizing their tax liability by taking advantage of cross-country differences, countries have implemented various anti-tax avoidance measures, such as the so-called Controlled Foreign Corporation (CFC) rules.

5 min read
international tax avoidance To help countries face the pandemic-related financing needs while reducing inequality, the International Monetary Fund (IMF) has released a series of policy recommendations based on a temporary COVID-19 tax, levied on high incomes or wealth. IMF tax proposals: shrink inequality or harm pandemic economic recovery? OECD work plan, BEPs 2.0, base erosion, profit allocation, global minimum tax, base erosion and profit shifting oecd

What We Know: Reviewing the Academic Literature on Profit Shifting

Lawmakers around the world are considering substantial changes to international tax rules to address tax avoidance. Many changes have already been made in recent years, with early economic evidence indicating that they may not only address tax avoidance but also impact business hiring and investment decisions.

5 min read
CFC rules in Europe, Controlled Foreign Corporation Rules in Europe 2020, CFC rules in Europe 2020

CFC Rules in Europe

To prevent businesses from minimizing their tax liability by taking advantage of cross-country differences in taxation, countries have implemented various anti-tax avoidance measures, one known as Controlled Foreign Corporation (CFC) rules.

5 min read
International Rankings of Germany's Tax System. Learn more about Germany tax system.

How Controlled Foreign Corporation Rules Look Around the World: Germany

Germany has had a Controlled Foreign Corporation (CFC) regime since 1972, when the German Foreign Transactions Tax Act was enacted. Under the German regime, a CFC is a foreign company where its capital or voting rights are either directly or indirectly majority-owned by German residents at the end of its fiscal year.

6 min read
Spain digital services tax Spain falling behind on digitalization, Spain Digital Tax, Digital Services Tax

How Controlled Foreign Corporation Rules Look Around the World: Spain

The CFC legislation in Spain is not as complicated as it is in some other countries, and it is aligned with the standards recommended by the OECD. The Spanish rules have evolved in a way that the rules are designed to comply with the EU principles not to interrupt the functioning of the Union and its single market.

4 min read
China CFC rules, China Controlled Foreign Corporation rules, Chinese controlled foreign corporation rules, Chinese multinationals

How Controlled Foreign Corporation Rules Look Around the World: China

The Chinese approach to base erosion and profit shifting is more focused on the application of transfer pricing rules and not on the application of CFC rules. Even with the rules in place, the Chinese tax authorities have not enforced the rules as much as other countries have.

3 min read
Brexit, UK tax system, UK CFC rules, UK controlled foreign corporation, UK BEPS

How Controlled Foreign Corporation Rules Look Around the World: United Kingdom

The UK rules are designed to arrive at the most accurate definition of foreign income that should be taxed in the home country. These rules apply one of the most detailed approaches to solving the issue of taxing the right type and amount of foreign income. The method can be considered more effective, but the compliance implications and derived costs may be higher compared to those that are derived from the application of other methods.

7 min read
Netherlands Controlled Foreign Corporation Rules. Netherlands CFC rules, Dutch tax system, Netherlands corporate tax, Netherlands tax

How Controlled Foreign Corporation Rules Look Around the World: Netherlands

The Dutch tax system is characterized by its simplicity and the attractiveness to investors. With the incorporation of CFC rules, the Dutch government protected its tax base from erosion and profit shifting. The Netherlands is facing a whole series of adjustments that would create a more complex system adapted to the international standards recommended by the OECD and adopted by the European Union Council. When revising the rules authorities must be mindful about not making the system more complex and to avoid increasing the compliance burden in the country.

5 min read