CFC-Regimes
Areas of Practice
CFC-Regimes
Most industrial Countries run CFC-Regimes (Controlled Foreign Companies) or adopt single Rules to avoid a double non-taxation of foreign entities. Income is then deemed as received even without distribution to a shareholder.
The tricky part is if someone did so over the past without declaring these non distributed profits, could end up in a Law Suit, triggering hefty fines and in some cases jail term.
Chenevieres Consulting SA (CCSA) advises its international clients about necessary steps. Get in touch to discuss your personal situation.
International Taxation
A professional team of Experts, specialized in International Taxation and focussed in Tax Consulting & Advisory with international experience, will bring you valuable high-end expert advice.
We take care of the whole process, from Accessing your personal circumstances, Tax Consulting and Advisory to suit fit your needs and implementation of better suitable structures.
We offer an initial Consultation free of charge via Skype.
International Taxation
Nowadays it is important to have ever increasing OECD Standards in mind to avoid possible Tax and Criminal Allegations through non-compliant and validated Corporate Structures. Speak to us to find out your Alternatives.
BEPS Action 3 – Strenghtening CFC-Rules
Action 3 of the BEPS ACTION PLAN stresses the need to address base erosion and profit shifting using a controlled foreign company (CFC) rules. Many countries already have CFC rules, but these rules do not always counter BEPS in a comprehensive manner.
While CFC rules in principle lead to inclusions in the residence country of the ultimate parent, they also have positive spillover effects in source countries because taxpayers have no (or much less of an) incentive to shift profits into a third, low-tax jurisdiction.
Now it’s time to discuss the latest developments with us.
Offshore or Onshore
It is surely not forbidden to own an Offshore Company for a legitimate purpose. However, if the only purpose of your Offshore entity is Tax Avoidance or even worse Tax Evasion, you should reconsider all options.
Through latest OECD developments – AEOI and CRS Standards – there is no space for any undeclared income or hidden assets.
Speak to us to find more about how to comply with national Tax rules.
FATCA
The Foreign Account Tax Compliance Act (FATCA) is intended to detect and deter the evasion of US tax by US citizens who hide money outside the US. This agreement shall create greater transparency by strengthening the flow of information, its reporting and compliance by providing rules around the processes of documenting, reporting and withholding on a payee.
FATCA rules do not only have an impact on the financial services sector but also affect many entities outside of the traditional financial services sector with operations both in and outside of the United States.
To find out more about FATCA and its regulatory framework speak to us.
International Taxation – Tax Relief
You may be taxed on your foreign income by ONE COUNTRY and by the country where your income is from.
You can usually claim tax relief to get some or all of this tax back. How you claim depends on whether your foreign income has already been taxed.
Speak to us if you are unsure of how to do so.
Foreign Tax Credits
Even if there is no double taxation agreement in place between your country of residence and the country where the income arises, tax relief may be available by means of a foreign tax credit.
For example, if you pay tax at 15% on your foreign income in the country in which the income arises, then you may still have to pay tax in the country of your tax residence If the tax rate there is 20%, you would only have to pay 5% of tax there, as you would be given a tax relief for the 15% of tax paid overseas.
In some cases, foreign income is even tax-free in your country of residence. Speak to us to find out more.