Sayfa 1103. Anti-Tax Avoidance Directive
3.1. Controlled Foreign Company (CFC) Rule (Articles 7 and 8)
Articles 7 and 8 of the ATAD implement the recommendations of the OECD/G20’s BEPS…
The CFC rule in the Directive has a huge impact on the corporate tax landscape in…
Moreover, a substance carve-out was designed to ensure the compatibility of the CFC…
In Cadbury Schweppes the application of CFC…
In Test Claimants in the Thin Cap Group Litigation…
In Fred Olsen the application of CFC rules to a foreign corporation constitutes a prohibited restriction of the freedom of establishment
Articles 7 and 8 of the ATAD seem to fulfil these substance requirements since they…
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