Normal view MARC view ISBD view

An investigation into the interaction of CFC Rules and the OECD Pillar Two Global Minimum Tax electrónico Brian J. Arnold

By: Arnold, Brian J .

Material type: Article

ArticleSubject(s): SOCIEDADES EXTRANJERAS CONTROLADAS

| IMPUESTO DE SOCIEDADES

| TIPO MÍNIMO GLOBAL

| SEGUNDO PILAR (OCDE)

In: Bulletin for International Taxation v. 76, n. 6, 2022, p. 270-289Summary: This article investigates the interaction between the controlled foreign corporation regimes of countries and the OECD Pillar Two Model Rules for a global 15% minimum tax. The author considers the interaction between the two sets of rules in depth, illustrating his findings by way of worked examples.

Tags from this library: No tags from this library for this title. Log in to add tags.

average rating: 0.0 (0 votes)

Holdings ( 1 )
Title notes
Comments ( 0 )
Images

Item type	Current location	Home library	Call number	Status	Date due	Barcode
Recursos electrónicos	IEF	IEF	BIT/2022/6-1 (Browse shelf)	Available		BIT/2022/6-1

Browsing IEF Shelves Close shelf browser

Previous	No cover image available	No cover image available	No cover image available	No cover image available	No cover image available	No cover image available	No cover image available	Next
Previous	BIT/2022/5-3 Article 12B of the UN Model (2021)	BIT/2022/5-4 Key decision of the Italian Supreme Court on the relationship between the concepts of beneficial ownership and abuse of tax treaties	BIT/2022/6 Bulletin for International Taxation	BIT/2022/6-1 An investigation into the interaction of CFC Rules and the OECD Pillar Two Global Minimum Tax	BIT/2022/6-2 The implications of the Supreme Court of Canada’s decision in Alta Energy Luxembourg (2021) for the OECD Principal Purpose Test	BIT/2022/6-3 The utility of tax residence tests beyond taxing rights and the concept of “tests of belonging” given the growing number of multilateral provisions in the context of territorial tax regimes with special reference to Gibraltar and Hong Kong	BIT/2022/7 Bulletin for International Taxation	Next

Resumen.

This article investigates the interaction between the controlled foreign corporation regimes of countries and the OECD Pillar Two Model Rules for a global 15% minimum tax. The author considers the interaction between the two sets of rules in depth, illustrating his findings by way of worked examples.

There are no comments for this item.

Click on an image to view it in the image viewer

Biblioteca del Instituto de Estudios Fiscales

An investigation into the interaction of CFC Rules and the OECD Pillar Two Global Minimum Tax electrónico Brian J. Arnold

By: Arnold, Brian J.

Browsing IEF Shelves Close shelf browser

By: Arnold, Brian J .