https://www.taxtmi.com/manuals?id=2895 CFC rules prevent profit shifting by attributing income of low tax foreign subsidiaries to controlling parents. BEPS Action Plan 3 recommends six building blocks: clear definitions of CFCs and CFC income; meaningful effective tax rate thresholds for exceptions; computation of attributed income using parent jurisdiction rules with limited loss offsets; attribution tied to control and proportionate ownership; and mechanisms to prevent or eliminate double taxation through foreign tax credits and relief on dividends or disposals. These recommendations are flexible to accommodate domestic policy and international obligations; India currently lacks specific CFC rules in its Income Tax Act. en-us Tue, 20 Jun 2023 16:28:00 +0530 Sat, 27 Jan 2024 13:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=2895 CFC rules prevent profit shifting by attributing income of low tax foreign subsidiaries to controlling parents. BEPS Action Plan 3 recommends six building blocks: clear definitions of CFCs and CFC income; meaningful effective tax rate thresholds for exceptions; computation of attributed income using parent jurisdiction rules with limited loss offsets; attribution tied to control and proportionate ownership; and mechanisms to prevent or eliminate double taxation through foreign tax credits and relief on dividends or disposals. These recommendations are flexible to accommodate domestic policy and international obligations; India currently lacks specific CFC rules in its Income Tax Act. Manuals Income Tax Tue, 20 Jun 2023 16:28:00 +0530 https://www.taxtmi.com/manuals?id=2895