A European model for member states' legislation on the taxation of controlled foreign subsidiaries (CFCs) - Part 1

The original paper that forms the basis of this article was drafted in response to the Commission Communication of 10 December 2007 regarding the application of anti-abuse measures for direct taxation, with specific reference to controlled foreign company (CFC) legislation, and to submit proposals to develop an EU model for this legislation. Part 1 considers the key aspects of CFC legislation.