Rules of Taxation of Controlled Foreign Companies: A Comparative Study

  •  Milyausha R. Pinskaya    
  •  Nina I. Malis    
  •  Nicolai S. Milogolov    


This article is aimed at generalization of foreign practices of taxation of Controlled Foreign Companies in orderto solve a problem of capital outflow to low-tax jurisdictions and at further elaboration of recommendations onreforming a concept of tax residence in the Russian Federation. The article summarizes elements of nationaltaxation rules set in such countries as France, Great Britain, Germany, USA, China and Brazil. The articledetects shortcomings of the Russian rules concerning Controlled Foreign Companies and suggests ways of theirremedy. It makes a conclusion that taking into consideration the Russian environment the rules concerning CFCbeing elaborated require careful revision with regard to recommendations of Organization of EconomicCooperation and Development which will be made in 2015 within the framework of a “Base Erosion and ProfitShifting” program.

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