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controlled foreign corporation rules

Bracing for Impact

Though they are limited by both data and assumptions, the OECD will face similar limitations. As policymakers work to fine-tune the proposals under both Pillar 1 and 2 the impact assessment should be a critical part of that discussion.

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

FAQ on Digital Services Taxes and the OECD’s BEPS Project

What is a digital services tax (DST)? What countries have announced, proposed, or implemented a DST? What are some of the criticisms of a DST? What are alternatives to a DST? What is the OECD BEPS project and what is its main objective? What is the main objective of OECD Pillar 1? What is the main objective of OECD Pillar 2?

8 min read
State Corporate Income Tax Rates and Brackets for 2019, state corporate tax rates 2020

State Corporate Income Tax Rates and Brackets, 2020

Forty-four states currently levy a corporate income tax. Rates range from 2.5 percent in North Carolina to 12 percent in Iowa. Over the past year, several states, including Florida, Georgia, Indiana, Mississippi, Missouri, and New Jersey, implemented notable corporate income tax changes.

7 min read
Davos digital tax proposals, French digital tax proposal, U.S. and France digital tax dispute agreement in Davos, Switzerland

The Davos Digital (Tax) Détente?

The past week has been nearly nonstop with news on various fronts of a dispute over taxation of digital businesses. The main characters have been the U.S., France, and the UK, although the EU and the OECD have also played roles. Though the dust is still settling, it is worth trying to tie the various events and arguments together.

7 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