Nature, purpose and effect of controlled foreign corporation rules. Their compatibility with the principles of international tax law
Increase in globalization and foreign trade in the last century led to aggressive tax planning. Though these planning measures are legitimate, they are designed for shifting profits to low tax jurisdictions. There is a number of measured to deal with this tax abuse. In particular, some jurisdictions apply controlled foreign corporation (CFC) rules.
Historically, the CFC concepts were created to help prevent tax evasion achieved by setting up offshore companies in tax havens, such as Bermuda...
Published:
02.10.2018
The concept of Non-Discrimination as expounded in Article 24 of the OECD Model Tax Convention on Income and on Capital
Non-discrimination articles have been used in tax treaties over a number of years, they are designed to place non-discrimination requirements on the source country rather than on the residence state.
There may arise cases where a country provides favourable treatment to its nationals and discriminates against foreigners. To circumvent such cases tax treaties provide a clause which restricts contracting states from offering discriminatory treatment to foreign nationals as compared to its...
Gaming business in Sweden
The Government of Sweden has decided to review its policy on gaming by adopting a bill on the legal regulation of gaming, the entry into force of which is planned for January 1, 2019.
The bill was supported by over 90% of the present members of Swedish Parliament. The only political force that voted against was the Left Party (ex-Communists). Nevertheless, it did not affect the final result.
The result of the adoption of this bill was the transition of Sweden to a regulated market of gaming...
Leasing of Real Estate by a Natural Person
Many citizens who own residential and non-residential real estate intend to lease it. But they have some questions: is it necessary to register as an entrepreneur in this case, are there any peculiarities in taxation and are there any restrictions?
According to Art. 319, 320 of the Civil Code of Ukraine - the owner owns, uses, disposes of his property at his own discretion and has the right to make any actions with respect to his property that do not contradict the law, including using his...
