Applying CFC rules to 'affiliates': critical elements for considerations
Article Abstract:
The Consolidated Tax Act provides for the treatment of controlled foreign corporations located in states with preferential tax treatment laws and in which such subjects reside in Italy. Article 168 of tax legislation pertains to tax policies concerning affiliated corporations. Amendments to the aforementioned tax law and its interpretation by tax courts are discussed.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2008
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Belgium: attribution of profits to permanent establishment
Article Abstract:
A method of assessing the profits of permanent establishments operating under Belgian tax law with respect to the OECD Model Tax Convention is explained. Only cross-border company profits are analyzed.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
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