A comparison by Taxand Cyprus
In 2019, the Organisation for Economic Cooperation and Development (OECD) proposed the Pillar Two rules to provide a solution to all unresolved issues of BEPS Actions 2–15. According to the October 2020 Pillar Two Blueprint, the GloBE primary rule, namely the income inclusion rule (IIR), operates as a “super” controlled foreign company (CFC)-like rule, but with a broader scope.
Christos Theophilou from our Cypriot firm, Taxand Cyprus, looks at the similarities and differences between the OECD Income Inclusion Rule and controlled foreign company rules. Further, he considers the six building blocks provided by the OECD BEPS Action 3 for designing a CFC regime.
Read the full article here.
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