The Permanent Representatives Committee of the Council of the European Union has approved the text of a draft resolution on co-ordination of the controlled foreign companies (CFC) and thin capitalisation rules within the European Union. The Annex to the draft resolution which contains the substantive detail of the resolution provides a non-exhaustive list of indicators suggesting that profits may have been artificially diverted or transferred to a CFC. These indicators include an artificial attribution of profits no proportionate correlation between the activities apparently carried on by the CFC and the extent of its premises staff or equipment over-capitalisation and arrangements that are devoid of economic reality and serve little or no business purpose.
In relation to thin capitalisation the Annex sets out a non-exhaustive list of indicators suggesting an artificial transfer of profits...
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The Permanent Representatives Committee of the Council of the European Union has approved the text of a draft resolution on co-ordination of the controlled foreign companies (CFC) and thin capitalisation rules within the European Union. The Annex to the draft resolution which contains the substantive detail of the resolution provides a non-exhaustive list of indicators suggesting that profits may have been artificially diverted or transferred to a CFC. These indicators include an artificial attribution of profits no proportionate correlation between the activities apparently carried on by the CFC and the extent of its premises staff or equipment over-capitalisation and arrangements that are devoid of economic reality and serve little or no business purpose.
In relation to thin capitalisation the Annex sets out a non-exhaustive list of indicators suggesting an artificial transfer of profits...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
