CFC conundrum how Brazil has safe harboured individuals in its efforts to combat tax avoidance Dora Pimentel Mendes de Almeida, Michell Przepiorka
By: Mendes de Almeida, Dora Pimentel
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Contributor(s): Przepiorka, Michell.
Material type: 
ArticlePublisher: 2021Subject(s): SOCIEDADES EXTRANJERAS CONTROLADAS | IMPUESTOS | ELUSION FISCAL | EVASION FISCAL | EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | PREVENCIÓN | BRASIL
In:
Intertax v. 49, n. 12, December 2021, p. 1013-1024Summary: This article discusses the general purpose of controlled foreign corporation (CFC) rules and how countries have extended them to individual taxpayers to combat the effects of base erosion and profit shifting. It also addresses how Brazil does not currently have CFC rules applicable to individuals in its tax system which has allowed for abusive tax planning and tax avoidance. Finally, this article discusses whether there are valid restrictions on the implementation of CFC rules that are applicable to controlling individuals in Brazil.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2021/12-5 (Browse shelf) | Available | OP 2141/2021/12-5 |
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| OP 2141/2021/12-2 Mandatory binding arbitration | OP 2141/2021/12-3 Can the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal? | OP 2141/2021/12-4 Critical review of the ATAD implementation | OP 2141/2021/12-5 CFC conundrum | OP 2141/2021/12-6 Abolition of DDT in India | OP 2141/2021/12-7 Recent trends in the jurisprudence of the CJEU regarding the right to deduct Input tax | OP 2141/2021/12-8 Protection of taxpayers’ personal data and national tax interest |
Resumen.
This article discusses the general purpose of controlled foreign corporation (CFC) rules and how countries have extended them to individual taxpayers to combat the effects of base erosion and profit shifting. It also addresses how Brazil does not currently have CFC rules applicable to individuals in its tax system which has allowed for abusive tax planning and tax avoidance. Finally, this article discusses whether there are valid restrictions on the implementation of CFC rules that are applicable to controlling individuals in Brazil.
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