OECD: Discussion draft, BEPS Action 3 (CFC rules)

OECD: Discussion draft, BEPS Action 3 (CFC rules)

The Organisation for Economic Co-operation and Development (OECD) today released a discussion draft under the base erosion and profit shifting (BEPS) project concerning BEPS Action 3 (strengthening CFC rules).

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The discussion draft [PDF 576 KB] under BEPS Action 3 focuses on developing recommendations for the design of controlled foreign company (CFC) rules to combat base erosion and profit shifting.

As noted in a related OECD release, the BEPS Action 3 discussion draft considers all the constituent elements of CFC rules and breaks them down into the “building blocks” that are necessary for effective CFC rules.

  • The majority of these building blocks include recommendations, and the building block that does not yet include a recommendation discusses possible options that could be included in effective CFC rules.
  • The discussion draft also identifies specific questions for which input is required in order to advance the work on CFC rules.

The work is to be completed by September 2015, and interested parties are invited to send comments on this discussion draft (due by 1 May 2015).

A public consultation meeting on BEPS Action 3 will be held in Paris on 12 May 2015.

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