Controlled Foreign Company Legislation, Corporate Residence and Anti-Hybrid Arrangement Rules

Journal
OECD
Bulletin for International Taxation 2014 (Volume 68), No. 6/7
An assumption of the OECD Base Erosion and Profit Shifting initiative is that a holistic approach should be adopted. This article suggests that the reshaping of controlled foreign company rules should be coordinated with changes to corporate tax residence and anti-hybrid arrangement rules.