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The uncertain future of CFC regimes in the member states of the European Union - part 2

Renata Fontana

Open publisher page 17 citations

Abstract

This article deals with the new issues arising in the EU context regarding controlled foreign company (CFC) regimes in respect of tax arbitrage within the Internal Market and distinguishing this from the concept of tax avoidance, based on the redefinition of the EC law concept of abuse of rights. The article, therefore, analyses the debate at three different levels, i.e. with regard to domestic law, tax treaties (both in part 1) and EC law, (in part 2).

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What this paper is about

This article deals with the new issues arising in the EU context regarding controlled foreign company (CFC) regimes in respect of tax arbitrage within the Internal Market and distinguishing this from the concept of tax avoidance, based on the redefinition of the EC law concept of abuse of rights. The article, therefore, analyses the debate at three different levels, i.e. with regard to domestic law, tax treaties (both in part 1) and EC law, (in part 2).

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OpenAlex reports 17 citations for this work. Citation counts describe recorded attention and do not establish research quality.

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Available abstract

This article deals with the new issues arising in the EU context regarding controlled foreign company (CFC) regimes in respect of tax arbitrage within the Internal Market and distinguishing this from the concept of tax avoidance, based on the redefinition of the EC law concept of abuse of rights. The article, therefore, analyses the debate at three different levels, i.e. with regard to domestic law, tax treaties (both in part 1) and EC law, (in part 2).

Key concepts: Context (archaeology), European union, Member states, Tax law, Law and economics, Political science, Economics, Domestic market

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The uncertain future of CFC regimes in the member states of the European Union - part 2 — Research Paper | ScholarLens