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OECD has invited comments on
a discussion draft which deals with action 3 (Strengthening CFC Rules) of
the BEPS Action Plan.
In July 2013, the Action Plan on Base Erosion and Profit Shifting directed
the OECD to commence work on 15 actions designed to ensure the coherence of
corporate income taxation at the international level. The first seven of these
actions were presented to G20 Leaders at the Brisbane Summit in November 2014.
Action 3 of the BEPS Action Plan focuses on developing recommendations for
the design of controlled foreign company (CFC) rules to combat base erosion
and profit shifting.
This discussion draft considers all the constituent elements of CFC rules and
breaks them down into the "building blocks" that are necessary for effective
CFC rules. The majority of these building blocks include recommendations, and
the building block that does not yet include a recommendation discusses possible
options that could be included in effective CFC rules. The discussion draft
also identifies specific questions where input is required in order to advance
the work on CFC rules. The options and recommendations included in this discussion
draft do not represent the consensus view of the Committee on Fiscal Affairs
(CFA) or its subsidiary bodies, but they are intended to provide stakeholders
with substantive options for analysis and comment.
The Action Plan calls for this work to be completed by September 2015. As part
of the transparent and inclusive consultation process mandated by the Action
Plan, the CFA invites interested parties to send comments on this discussion
draft.
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