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Two's company, three's a crowd electrónico the triad of controlled foreign company rules and the two-sided income inclusion rule under the OECD's Pillar Two Global Minimum Tax proposal Michael Lindgren

By: Lindgren, Michael.
Material type: ArticleArticleSubject(s): FISCALIDAD INTERNACIONAL | SOCIEDADES EXTRANJERAS CONTROLADAS | SEGUNDO PILAR (OCDE) | TIPO MÍNIMO GLOBAL In: Bulletin for International Taxation v. 77, n. 1, January 2023, p. 21-31Summary: This article analyses multiple issues and offers recommendations regarding the overlap between standard controlled foreign company rules and the income inclusion and qualified domestic minimum top-up tax rules of the OECD’s Pillar Two Global Minimum Tax proposal.
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Disponible únicamente en formato electrónico a través de la plataforma IBFD en la Biblioteca del IEF.

This article analyses multiple issues and offers recommendations regarding the overlap between standard controlled foreign company rules and the income inclusion and qualified domestic minimum top-up tax rules of the OECD’s Pillar Two Global Minimum Tax proposal.

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