A European model for member states' legislation on the taxation of controlled foreign subsidiaries (CFCs) - Part 2

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 2 contains a comparative survey and an assessment of the distorting effects of CFC legislation in four Member States, and sets out proposals concerning "best practice" for such legislation.