This article focuses on the challenges presented by the controlled foreign company rules in articles 7 and 8 of the EU Anti-Tax Avoidance Directive, not purely from a technical standpoint, but also from the perspective of tax policy.
This article focuses on the challenges presented by the controlled foreign company rules in articles 7 and 8 of the EU Anti-Tax Avoidance Directive, not purely from a technical standpoint, but also from the perspective of tax policy.