: Alexandra Miladinovic, Nathalie Bravo
: Concept and Implementation of CFC Legislation Series on International Tax Law, Volume 124
: Linde Verlag Wien Gesellschaft m.b.H.
: 9783709411599
: Schriftenreihe zum Internationalen Steuerrecht
: 1
: CHF 72.00
:
: Steuern
: English
: 536
: DRM
: PC/MAC/eReader/Tablet
: ePUB

An in-depth analysis of various aspects of CFC legislation

This volume provides an in-depth analysis of various aspects of the topic“Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law.


Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.

IXList of Authors


Olena Bokan

Olena Bokan was born in the Ukraine in 1980. She graduated with an MSc in Economics from Kyiv National University of T.Shevchenko (Ukraine) in 2003. In 2006, she obtained an MSc in Business and IT from the Aston University (UK). In her early career years, she worked as a financial controller in Ukrainian and international companies. In 2011, she established her own consultancy company in Kyiv in the area of international business and taxation. Since 2019 she is based in Prague and runs there a consulting company. She provides consulting services in the area of international taxation, investments, and various business matters to domestic and international clients.

Serena Bussotti

Serena Bussotti received a degree in economics and business law at Bocconi University in Milan, Italy. She has been working as a transfer pricing and international tax