An Investigation into the Interaction of CFC Rules and the OECD Pillar Two Global Minimum Tax
Journal
International; OECD
Bulletin for International Taxation 2022 (Volume 76), No. 6
This article investigates the interaction between the controlled foreign corporation regimes of countries and the OECD Pillar Two Model Rules for a global 15% minimum tax. The author considers the interaction between the two sets of rules in depth, illustrating his findings by way of worked examples.