| Tittel: | Discriminatory tax treatment of CFC’s losses towards losses of partnerships, economic double taxation, exchange of tax information and future developments of the Norwegian CFC rules | | Ansvar: | Błażej Kuźniacki | | Forfatter: | Kuzniacki, Blazej  | | Materialtype: | Artikkel - elektronisk | | Signatur: | Skatterett | | Utgitt: | Oslo : Universitetsforlaget, 2014 | | Omfang: | s. 349-384 | | Serie: | Skatterett ; 4/2014 | | Innhold: | This article focuses on selected issues related to the compatibility of the Norwegian CFC rules with the EEA law; namely, discriminatory tax treatment of CFC’s losses and economic double taxation. It will be also analysed whether the restrictions of fundamental freedoms may be justified by the lack of the applicability of a legal instrument for exchanging tax information with tax authorities of a CFC’s resident state. Finally, the author will provide conclusions and his thoughts on future developments regarding the CFC rules – Action Plan on BEPS and the necessity for introducing the new exemption from their application, i.e. “genuine economic activities exemption”. | | Del av verk: | Skatterett 4/2014 |
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