Concept and Implementation of CFC Legislation (eBook)

Series on International Tax Law, Volume 124

Alexandra Miladinovic, Nathalie Bravo (Herausgeber)

eBook Download: EPUB

2021 | 1. Auflage
536 Seiten
Linde Verlag Wien Gesellschaft m.b.H.
978-3-7094-1159-9 (ISBN)

Infos

An in-depth analysis of various aspects of CFC legislation

This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law.

Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.

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IXList of Authors

Olena Bokan

Olena Bokan was born in the Ukraine in 1980. She graduated with an MSc in Economics from Kyiv National University of T.Shevchenko (Ukraine) in 2003. In 2006, she obtained an MSc in Business and IT from the Aston University (UK). In her early career years, she worked as a financial controller in Ukrainian and international companies. In 2011, she established her own consultancy company in Kyiv in the area of international business and taxation. Since 2019 she is based in Prague and runs there a consulting company. She provides consulting services in the area of international taxation, investments, and various business matters to domestic and international clients.

Serena Bussotti

Serena Bussotti received a degree in economics and business law at Bocconi University in Milan, Italy. She has been working as a transfer pricing and international tax consultant since 2012 at an Italian tax firm mainly based in Milan, Pirola Pennuto Zei & Associati.

Fernanda Freitas Maciel

Fernanda Freitas Maciel was born in Pompéu, Minas Gerais, Brazil, in 1990. In 2015, she graduated in law at the Federal University of Ouro Preto, Brazil and, in 2019, she graduated in Accounting at the Pontifical Catholic University of Minas Gerais, Brazil. Currently, she is a transfer pricing consultant at Ernst & Young in Zurich, Switzerland.

Federico Giordano

Federico Giordano was born in Italy. In 2007, he graduated with honours from the University of Urbino with a degree in Business Administration. During his studies, he attended exchange study programmes in the United Kingdom and the United States. From 2007 to 2010, he worked in Milan at Big4 accounting firms, providing tax counsel in connection to both domestic and international tax matters, as well as M&A transactions and Real Estate practice, with a particular focus on REIFs and Trusts. In 2009, he obtained a Master’s degree with full marks in tax law from Bocconi University in Milan. Since 2010, he has been working as an international tax advisor (salary partner from 2016) for both individuals and corporations at Marchionni & Partners; a regional tax and legal firm based in Italy and part of HLB International, a global network of independent advisory and accounting firms. In 2017, he was on secondment at Withum Smith+Brown, in New York. He is a statutory auditor for companies operating in manufacturing and other industries.

XLydia Gregorova

Lydia Gregorova graduated from the Faculty of Economics at Matej Bel University in Slovak Republic, and she received a degree in Public Economics and Administration. She has a finance and tax background, and she currently works as the Tax Country Lead Slovakia in Swiss Re in Bratislava.

Francesco Grieco

Francesco Grieco is a lawyer and certified public accountant who graduated from Bocconi University in Italy and had executive education at Harvard University in the United States. He has been working in China, Italy, and Luxembourg in the field of international taxation since 2013. Since then, he has worked within the network of BonelliErede, PricewaterhouseCoopers, and a company listed on the Dublin ISEQ and London stock exchanges, and teached transfer pricing and international taxation within graduate courses. Currently, he is working as a global international tax and transfer pricing specialist for a multinational company in Switzerland operating in the Oil & Gas industry.

Hannes Hilpold

Hannes Hilpold received a degree in business administration at the Leopold-Franzens-Universität Innsbruck in Austria. He has been working as a tax consultant and auditor in several international tax law firms in Milan (Italy) since 2006. Currently, he is tax advisor and partner at Bureau Plattner Milan (Italy).

Mike Kollar

Mike Kollar completed his degree in economics at the University of Economics in Bratislava Slovakia where he graduated with honors. He started in tax advisory, became a certified tax advisor in 2018, and is currently working in a senior role in the global tax department of ESET, one of the leading cybersecurity providers.

Jovdat Mammadov

Jovdat Mammadov was born in Baku, Azerbaijan. He holds the MBA academic title, jointly awarded by Wirtschaftsuniversität Wien and Technische Universität Wien. Previously, he received his master’s degrees in law from Kutafin Moscow State Law University (MSAL) and in international relations from Diplomatic Academy of the Ministry for Foreign Affairs of Russia. From 2000 to 2011, he worked for the Organization for Security and Cooperation in Europe (OSCE) in various legal and managerial roles and, in 2012, he joined the United Nations (UNO) where he develops capacity-building programs and advises the organization on policy issues.

Niki Mitrakou

Niki Mitrakou graduated from the Faculty of Law and holds an LL.M in European Law from the National and Kapodistrian University of Athens. She is a qualXIified lawyer with work experience in law firms in Greece and Germany and has worked from 2018 to 2020 in the legal and compliance department of a leading US alternative investment firm, in Luxembourg. Currently, she is a tax advisor at PricewaterhouseCoopers in Athens.

Ludovica Ostorero

Ludovica Ostorero was born in Turin in 1983. In 2007, she completed her studies in Business and Accounting at Università degli Studi di Torino and graduated with honors. After a period of study in the United States, she started working in 2009 and, since 2012, she has been a certified public accountant and auditor. She currently works as a tax consultant in Turin, and she is a member of the Scuola di Alta Formazione of Turin.

Anca Pianoschi

Anca Pianoschi is a Romanian-American economist with extensive experience in banking, management, and taxation. She has a degree in International Economic Affairs from Babes-Bolyai University (BBU) Cluj-Napoca, Romania. Currently, she is running a consultancy boutique firm in Romania, offering mainly tax advice to domestic and foreign companies.

Kristína Reguliová

Kristína Reguliová received a degree in economics at the University of Economics in Bratislava in the Slovak Republic. Currently, she is a senior tax consultant at BMB Partners in Bratislava.

Peter Van Rompaey

Peter Van Rompaey received a Master’s degree in Political and Social Sciences (KU Leuven, Belgium) and a Master’s degree in Commercial and Financial Sciences – Tax law (EHSAL, Belgium). He is also a holder of the Vienna Transfer Pricing Certificate. In the past, he has worked for the Belgian tax authorities and a Big4 firm. As of 2000, he is a certified tax advisor. He is tax partner at RSM Belgium in Brussels, since 2007, dealing with national and international tax services for companies.

Rodrigo Saavedra Zepeda

Rodrigo Saavedra Zepeda earned his licentiate degree in law from Universidad Rafael Landívar and was admitted to practice in Guatemala in 2014. In 2017, he completed the LL.M. in International Law at the Graduate Institute of International and Development Studies (IHEID) in Geneva, Switzerland. Rodrigo has extensive experience advising both clients and governments on how to increase their competitiveness and impact through international trade. Currently, he works for the United Nations Conference on Trade and Development (UNCTAD), assisting deXIIveloping countries in assessing their readiness to better engage in and benefit from e-commerce for development.

Iva Uljanić Škreblin

Iva Uljanić Škreblin received a degree in economics at the University of Zagreb, Faculty of Economics and Business, in the Republic of Croatia, in 2004. From 2004 until 2019, she worked at the Croatian Tax Administration as an income tax advisor and was also the first fiscal attaché of the Republic of Croatia since its full membership in the European Union. She represented the Republic of Croatia in working groups of the Council of the European Union for direct and indirect taxation. She is now working as a tax advisor at Primus savjetovanje in Zagreb.

Benjamin Florian Vlasich

Benjamin Florian Vlasich was born in 1986 in Austria. He has a degree in business law from the Vienna University of Economics and Business. In 2009, he started working for multiple tax advising companies. Then in 2015, he was publicly appointed as a tax advisor, in Austria. Since 2016, he has become a self-employed partner of an Austrian Tax Advising company, in Vienna.

Patrick Walchhofer

Patrick Walchhoferreceived a degree in Business and Economics at the Vienna University of Business and Economics. He has been working in various fields of national and...

Produkt-Details

• Erscheint lt. Verlag: 21.9.2021
• Sprache: englisch
• Themenwelt: Recht / Steuern ► Steuern / Steuerrecht
• ISBN-10: 3-7094-1159-9 / 3709411599
• ISBN-13: 978-3-7094-1159-9 / 9783709411599