Template-Type: ReDIF-Article 1.0
Author-Name: Nikolai S. Milogolov
Author-Email: nikmilogolov@gmail.com
Author-Workplace-Name: Financial Research Institute, Moscow 127006, Russia
Author-Name: Milyausha R. Pinskaya
Author-Email: MPinskaya@yandex.ru
Author-Workplace-Name: Financial Research Institute, Moscow 127006, Russia
Title: Controlled Foreign Company Rules: Comparative Analysis
Abstract: The purpose of this article is to summarize CFC rules in foreign countries and to work out recommendations on reforming tax residence institute in Russia. There is a review of national CFC rules, which are in force in France, United Kingdom, Germany, USA, China and Brazil. Proposed Russian CFC rules are also analyzed in this article. Main result is that proposed Russian CFC rules need further development and should be coordinated with OECD recommendations on this issue coming up in 2015.
Classification-JEL:
Keywords: controlled foreign company, corporate profit tax, tax residence, offshore jurisdiction,tax avoidance
Journal: Finansovyj žhurnal — Financial Journal
Pages: 36-46
Issue: 4
Year: 2014
Month: December
File-URL: http://www.nifi.ru/images/FILES/Journal/Archive/2014/4/04.pdf
File-Format: Application/pdf
Handle: RePEc:fru:finjrn:140404:p:36-46