Controlled Foreign Company Legislation, Corporate Residence and Anti-Hybrid Arrangement Rules

Guglielmo Maisto

Research output: Contribution to journalArticle

Abstract

An assumption of the OECD Base Erosion and Profit Shifting initiative is that a holistic approach should be adopted. This article suggests that the reshaping of controlled foreign company rules should be coordinated with changes to corporate tax residence and anti-hybrid arrangement rules
Original languageEnglish
Pages (from-to)327-331
Number of pages5
JournalBULLETIN FOR INTERNATIONAL TAXATION
Volume2014
Publication statusPublished - 2014

Keywords

  • legislation
  • residence

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