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Contribution Details
| Type | Master's Thesis |
| Scope | Discipline-based scholarship |
| Title | Base Erosion and Profit Shifting through Controlled Foreign Companies |
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| Institution | University of Zurich |
| Faculty | Faculty of Business, Economics and Informatics |
| Number of Pages | 61 |
| Date | 2016 |
| Abstract Text | The thesis discusses controlled foreign company rules within the broader topic of case erosion and profit shifting. Basis is the Action Step 3 of the OECD/G20 BEPS project. Action Step 3 contains the OECD's recommendation for effectively designing controlled foreign company (CFC) rules. The thesis of the three parts. The first part provides a general introduction to the CFC rules, describes how they work and lists the six building blocks CFC rules are made of. Also, it contains an explanation of the U.S. tax avoidance system working though Limitation on Benefits (LOB) clauses. The second part gives a detailed overview over the OECD's recommendation for CFC rules. It discusses policy considerations and recommendations on how to effectively design the six building blocks of CFC rules. The third part gives an overview over the CFC rules and regulations of the following jurisdictions: The United Kingdom, the United States, Germany, Switzerland, and Russia. In conclusion, the thesis raises the question if the effects of the 2015 OECD/G20 BEPS project are lasting and names three reasons why they are likely to be. |
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