“Two’s Company, Three’s a Crowd” – The Triad of Controlled Foreign Company Rules and the Two-Sided Income Inclusion Rule under the OECD’s Pillar Two Global Minimum Tax Proposal

Journal
Lindgren, M.
International; OECD
Bulletin for International Taxation 2023 (Volume 77), No. 1
Format/Price
JournalUSD 45

This article analyses multiple issues and offers recommendations regarding the overlap between standard controlled foreign company rules and the income inclusion and qualified domestic minimum top-up tax rules of the OECD’s Pillar Two Global Minimum Tax proposal.