The OECD on May 5 released public comments to an OECD discussion draft that provides recommendations on how countries can design effective controlled foreign companies (CFC) rules to combat base erosion and profit shifting (BEPS).
Sixty-two comments were released in response to the guidance, issued April 3 in response to action 3 of the OECD/G20 BEPS plan.
The discussion draft identifies and makes recommendations concerning the following seven “building blocks” considered necessary for effective CFC rules: (1) definition of a CFC, (2) threshold requirements, (3) definition of control, (4) definition of CFC income, (5) rules for computing income, (6) rules for attributing income, and (7) rules to prevent or eliminate double taxation.
The stakeholder input will be discussed during a public consultation to be held May 12 at the OECD Conference Centre in Paris. The meeting will be broadcast live on the internet.
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