Controlled Foreign Corporation Rules and Cross-Border M&A Activity [PDF]
We investigate the influence of one main anti tax avoidance measure, controlled foreign corporation (CFC) rules, on cross-border merger and acquisition (M&A) activity on a global scale. Using three different statistical methods and a large M&A data set, we find that CFC rules distort ownership patterns due to a competitive advantage of multinational ...
Hagen, Dominik von, Prettl, Axel
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The taxation of controlled foreign corporations’ income and its selected consequences [PDF]
Purpose – The aim of this study is an evaluation of the possibility of maximising budget income due to the tax regulations concerning controlled foreign corporations. The objective is to gain an understanding of these regulations for shaping the profitability of the investments performed abroad.
Jacek Uchman
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Profit Shifting & Controlled Foreign Corporation Rules the Thin Bridge between Corporate Tax Systems
At present, controlled foreign corporation (CFC) rules are one of the three main anti-tax avoidance laws in developed countries. This paper examines the different CFC rule settings in the OECD and additional countries to show their effects on profit shifting of multinational companies.
Axel Prettl
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Controlled Foreign Corporation and Importance of Exchange of International Information
Countries that want to take a share from the funds and capital flows of the saving countries and companies have started to make tax arrangements in order to get a share from the market in question with their unfair competition.
Taner Ercan
doaj +2 more sources
Impact of Controlled Foreign Corporation Rules on Post-Acquisition Investment and Profit Shifting in Targets [PDF]
We investigate real investment, financial revenues and profits in formerly domestic firms once they enter a multinational entity (MNE) through an acquisition. We argue that following the acquisition, those targets are tax-optimized in a profit shifting context if they are acquired by MNEs with no controlled foreign corporation (CFC) rules in their ...
Hagen, Dominik von, Harendt, Christoph
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Taxable income differences between foreign and domestic controlled corporations in Norway
Studies mainly in the United States and United Kingdom have documented that foreign controlled corporations (FCCs) report significantly lower taxable income compared to domestic controlled corporations (DCCs). This taxable income differential has been partly attributed to income shifting by multinational corporations. Using a sample of 78,879 firm-year
John Christian Langli † +1 more
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The Impact of Controlled Foreign Corporation (CFC) Rules on Stock Market Reactions [PDF]
Abstract Prior to 2023, Taiwan had not yet implemented Controlled Foreign Corporation (CFC) rules, allowing multinational corporations to establish paper companies in low-tax countries or regions to avoid domestic corporate income tax by retaining earnings offshore without repatriation.
Hsieh Tsung-Yu +3 more
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An Economic Rationale for Controlled-Foreign-Corporation Rules [PDF]
By introducing controlled-foreign-corporation (CFC) rules, the parent country of a multinational firm reserves the right to tax the income of the firm's foreign affiliates, if the tax rate in the affiliate's host country is below a specified threshold.
Mardan, Mohammed +2 more
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Tax havens and controlled foreign corporations in the European Union
The subject of tax avoidance and evasion by use of tax havens has been addressed in the Organization for Economic Cooperation and Development (OECD) and G-20 industrialized nation for many years. However, taxpayers can always find the loopholes to minimize the tax payments prior to when new regulation comes out.
Kam Mei Kei
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