Übersetzung für "Cfc rules" in Deutsch

What is the main feature of the CFC Rules?

Taxation of foreign companies controlled by a Czech entity ("CFC rules")

These are largely tax-based provisions, such Controlled Foreign Company (CFC) rules or the refusal of normal tax exemptions or deductions for payments made to companies in the listed countries.

The scope of CFC rules is generally defined by reference to criteria regarding control, effective level of taxation, activity and type of income of the CFC, and they typically provide that profits of a CFC may be attributed to its domestic parent company and subjected to current taxation in the hands of the latter.

CFC rules may therefore continue to perform a useful function as an adjunct to rules on corporate residence and transfer pricing in so far as they provide a means of combating the more artificial types of tax planning, i.e. diversion of (paper) profits to controlled companies which are not genuinely established in other MSs or EEA States.

The limits on the permitted scope of CFC-type rules are without prejudice to the application of transfer pricing rules, which may be used more generally to target non-commercial pricing arrangements between associated companies.

Controlled Foreign Company (CFC) rules have the effect of re-attributing the income of a low-taxed controlled subsidiary to its parent company.

CFC rules re-attribute the income of a low-taxed controlled foreign subsidiary to its parent company.

CFC rules should exclude financial undertakings from their scope where those are tax resident in the Union, including permanent establishments of such undertakings situated in the Union.

In that regard, it is necessary that CFC rules extend to the profits of permanent establishments where those profits are not subject to tax or are tax exempt in the Member State of the taxpayer.

CFC rules extend to the profits of permanent establishments where those profits are not subject to tax or are tax exempt in the Member State of the taxpayer.

This is because the scope for a legitimate application of CFC rules within the Union should be limited to artificial situations without economic substance, which would imply that the heavily regulated financial and insurance sectors would be unlikely to be captured by those rules.

For example, all Member States will now have the power to tax profits being moved to low-tax countries where the company does not have any genuine economic activity (CFC rules).

Under CFC rules, the profits of a subsidiary receive different tax treatment for the sole reason that the subsidiary is resident in another State.

Depending on the policy priorities of that State, CFC rules may target an entire low-taxed subsidiary or be limited to income which has artificially been diverted to the subsidiary.

The other rules, i.e. the exit tax, CFC rules and hybrid mismatch arrangements, should be implemented to the extent proposed by the Directive.

This presentation explains - succinctly and by graphical illustration - the functioning of the CFC-Rules, their development at the OECD and EU level and their implications for Switzerland.

The draft CFC rules provide for taxation at 19 percent on income of Polish companies having at least 25 percent of shares (in the share capital, voting rights or participation in profits) in foreign subsidiaries, which, in turn, generate a total of at least EUR 250 thousand of annual income and which receive at least 50 percent of such income by way of financial transfers, if in the country of the registered office of these companies such income is taxed at a rate lower than 75 percent of the Polish CIT rate, i.e. lower than 14.25 percent.

Firstly, on 18 March 2014, the Council of Ministers adopted a draft amendment to the Corporate Income Tax Act and the Personal Income Tax Act, which is to introduce Controlled Foreign Corporation (CFC) rules in Poland.

The CFC rule will allow the Member State where the parent company is located to tax any profits that the company parks in a no or low tax country.

The CFC rule will allow the Member State where the parent company is located to tax certain profits that the company parks in a no or low tax country.

With the proposed CFC rule, the EU Member State can tax the subsidiaries profits as though they had not been shifted to the no-tax country, thereby ensuring effective taxation at the tax rate of the Member State concerned.

With the proposed CFC rule, the EU Member State can tax the insurance company's profits as though they had not been shifted to the no-tax country, thereby ensuring effective taxation at the tax rate of the Member State concerned.