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Applying CFC rules to 'affiliates': critical elements for considerations

Article Abstract:

The Consolidated Tax Act provides for the treatment of controlled foreign corporations located in states with preferential tax treatment laws and in which such subjects reside in Italy. Article 168 of tax legislation pertains to tax policies concerning affiliated corporations. Amendments to the aforementioned tax law and its interpretation by tax courts are discussed.

Author: Peracin, Gianfranco, De Luca, Alberto
Publisher: Aspen Publishers, Inc.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2008
Italy, Europe, Tax Law, Public Finance Activities, Interpretation and construction, Taxation, European Union. European Commission, Controlled foreign corporations

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Belgium: attribution of profits to permanent establishment

Article Abstract:

A method of assessing the profits of permanent establishments operating under Belgian tax law with respect to the OECD Model Tax Convention is explained. Only cross-border company profits are analyzed.

Author: Wustenberghs, Tim
Publisher: Aspen Publishers, Inc.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
Legal issues & crime, Government regulation (cont), Government regulation, Corporate Profits, Belgium, Legal/Government Regulation, Laws, regulations and rules, Measurement, Profit, Profits

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Subjects list: Tax policy, Report
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