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GFIA Documents on OECD Discussion Draft on BEPs Action 3: Strengthening CFC Rules


Release Date: 05/01/2015
Staff Reference: Janice Hilchie

The proposals in the discussion draft are complicated and conflicting, partly because they need to address both worldwide and territorial tax systems, which has resulted in inconsistencies due to the fundamental differences between the two approaches. It is not clear how the recommendations in the discussion draft interrelate with the other BEPS Actions, making it difficult to consider these recommendations in isolation.