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["Информация о файле"]
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["Часть","1 из 1"]
["Строк в этой части","947"]
["Всего строк","947"]
["Столбцов","7"]
["Создано","2025-11-07 15:39:21"]
["Размер исходного файла","0.06 MB"]
[]
["Структура данных"]
["Название столбца","Тип данных"]
["DATAFLOW","BYTE_ARRAY"]
["REF_AREA","BYTE_ARRAY"]
["FREQ","BYTE_ARRAY"]
["MEASURE","BYTE_ARRAY"]
["REGIME","BYTE_ARRAY"]
["TIME_PERIOD","INT64"]
["OBS_VALUE","BYTE_ARRAY"]

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["DATAFLOW","REF_AREA","FREQ","MEASURE","REGIME","TIME_PERIOD","OBS_VALUE"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","EXE","REGIME1",2019,"Austria opted to implement the two exemptions stipulated in Article 7 paragraph 3 ATAD 1."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","DEF","REGIME1",2019,"Generally, a CFC is a foreign affiliate that is legally controlled by the Canadian shareholder, or that would be controlled by the shareholder if the shareholder owned all of the shares of the foreign corporation that are owned by the taxpayer, persons that do not deal at arm's length with the taxpayer, and any other four Canadian residents. A foreign affiliate of a Canadian taxpayer is a non-resident corporation, where at least 1 percent of the shares of any class are owned, directly or indirectly, by the Canadian shareholder and at least 10 percent of the shares of any class are owned, directly or indirectly, by the Canadian shareholder together with related persons."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CUW","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","EXE","REGIME1",2019,"An exemption from CFC taxation exists for intermediate local holding companies. In principle, transactions between a subsidiary resident in the same country and the intermediate holding company are disregarded."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","DEF","REGIME1",2019,"A foreign entity, provided that the requirements for ownership (at least 25 % by the taxpayer itself or together with associated enterprises) and low tax rate (the actual corporate tax paid by the foreign entity on its profits is lower than three fifth's of the tax that would've been payable on the same income according to Finnish corporate income tax rules) are fulfilled."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","SUB","REGIME1",2019,"CFC rules do not apply in cases where the legal person or entity is resident for tax purposes in an EU member state, unless the establishment or financial activity of the legal person or entity constitutes a fictitious arrangement made essentially with the intention to avoid the applicable tax. In case the legal person or entity is resident for tax purposes in a country which is a party to the EEA agreement and an information exchange agreement is in force and implemented commensurate with the exchange of information upon request provided in Directive 2011/16/EU, CFC rules do not apply, unless the establishment or financial activity of the legal person or entity constitutes a fictitious arrangement made essentially with the intention to avoid the applicable tax."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","DEF","REGIME1",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","YEAR","REGIME1",2019,"2010"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KEN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KNA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","SUB","REGIME1",2019,"Yes, if the CFC actively engages in business operations through an office, a shop, or a factory, in the foreign jurisdiction then the CFC rules will not apply. This exemption, however, does not apply to a CFC: (i) which is engaged in certain businesses such as wholesale trade, financial and insurance business, real estate, lease business, etc. or (ii) which derives passive incomes from holding stocks or bonds, provision of intellectual property rights, leasing of vessels, aircraft, and heavy equipment, etc."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","DEF","REGIME1",2019,"Implementation of switch over provisions for dividends (see Art. 48 para. 3 letter b of the Tax Act)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","YEAR","REGIME1",2019,"2004"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","DEF","REGIME1",2019,"Malta has implemented the EU Council Directive 2016/1164. The constituent elements of a CFC is determined on the level of a control maintained by the controlling entity and the level of the effective taxation levied in the jurisdiction of the CFC."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","EXE","REGIME1",2019,"Beyond the above described exemption, there is no exemption or exclusion from the Polish CFC rules. However, low actual tax paid by a CFC may be considered as a kind of exclusion from the Polish CFC rules - the tax actually paid by the CFC is lower than the difference between the corporate income tax that would have been charged on the CFC under the Polish tax system and the actual corporate income tax paid by the CFC. For example, if the CFC actually paid more than 9,5 per cent of tax (50% of the Polish 19% ordinary tax rate for corporate taxpayers), while the corresponding Polish company would have been paid 19%, then the CFC's is excluded from the taxation under the Polish CFC rules (in fact such company would not be considered as a CFC because it will not meet on of the three conditions to become a CFC, i.e. low level of actual taxation)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","DEF","REGIME1",2019,"The control test is in line with the Article 7(1) of the EU Anti-Tax Avoidance Directive 2016/1164 (ATAD). The control test for a control foreign company is as follows [ITA Sec. 17h para 1 letter a)]: a corporate taxpayer (tax resident of the Slovak Republic) by itself, or together with its associated enterprises owns directly or indirectly more than 50% of the capital or holds a direct or indirect participation of more than 50% of the voting rights or is entitled to receive more than 50% of the profits of the foreign entity. Other condition, which has to be fulfilled is a tax rate test, i.e. the corporate tax paid by the controlled foreign company abroad is lower than the difference between the corporate tax of the controlled foreign company calculated under the Slovak Income Tax Act and the corporate tax paid by the controlled foreign company abroad [ITA Sec. 17h para 1 letter b)]. As the controlled foreign company is considered also the permanent establishment [ITA Sec. 17h para 3]. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","DEF","REGIME1",2019,"A CFC is any foreign corporation if more than 50% of the total combined voting power of all classes of stock of such corporation entitled to vote or the total value of the stock of such corporation is owned directly or indirectly by United States shareholders (U.S. shareholder) on any day during the taxable year of such foreign corporation. A U.S. shareholder is defined as a United States person (U.S. person) who owns 10 percent or more of the vote or value of all classes of stock of a corporation. Constructive ownership rules can attribute foreign stock ownership of one person to a related person."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRB","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CMR","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CRI","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CYM","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","SUB","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","YEAR","REGIME1",2019,"2000"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GAB","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","DEF","REGIME1",2019,"A CFC is defined as a company resident outside of Ireland that is controlled by an Irish resident company. An Irish resident company is considered to have control of a non-resident subsidiary where (in broad terms) it has direct or indirect ownership of or entitlement to more than 50% of the share capital, voting power or distributions."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","EXE","REGIME1",2019,"Not applicable."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","DEF","REGIME1",2019,"Under the CFC regime in Israeli tax law, an Israeli company or individual may be taxed on a proportion of certain undistributed profits of certain Israeli-controlled, non-resident companies in which the Israeli shareholder has a controlling interest (10% or more of any of the CFC’s ‘means of control’)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","EXE","REGIME1",2019,"The income to be taxed under the CFC rule shall be determined in accordance with Regulation 23F of the Income Tax Regulations 1996. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MYS","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","SUB","REGIME1",2019,"See question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","SUB","REGIME1",2019,"There is a de minimis rule if less than 5% of income is attributed income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PNG","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","YEAR","REGIME1",2019,"2015"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","QAT","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","EXE","REGIME1",2019,"The following shall not be considered controlled foreign companies according to the provisions of the law: a) the entity or the permanent establishment, if this registers in a fiscal period incomes from the categories mentioned by the law, representing one third or less than one third of the total incomes recorded in the calculated fiscal period; b) the financial enterprise which records in a fiscal period incomes of the nature provided in the law arising out of operations performed with the Romanian taxpayer or its associated enterprises, representing one third or less than one third of the total incomes registered by the financial undertaking."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","YEAR","REGIME1",2019,"2018"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VNM","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","DEF","REGIME1",2019,"CFC rules apply where more than 50% of the participation or voting rights in a foreign company are directly or indirectly exercisable by South African residents. The rules are partially relaxed in relation to listed companies.  Foreign companies include protected cell companies, which means they include foreign companies held via trusts or foundations, if such companies are consolidated by a South African resident company under IFRS10."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","DEF","REGIME1",2019,"A foreign company will be considered as a CFC if the following two conditions are simultaneously satisfied:  - The control test: the Belgian taxpayer owns (directly or indirectly) the majority of voting rights of the foreign company, or has (directly or indirectly) a stake of at least 50% in the capital of this company, or is entitled to at least 50% of the profits of this company; and  - The taxation test: in the country or jurisdiction where it is situated, the foreign company/PE is either not subject to income tax or subject to income tax less than half of the income tax if the company would have been located in Belgium."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","DEF","REGIME1",2019,"Control test criteria consider a foreign entity to be controlled if residents of Chile have:  - 50% or more of the foreign entity's capital, profits or voting power;  - the power to elect the majority of directors or administrators of the foreign entity; or  - the power to unilaterally amend the foreign entity's by laws, or to change the majority of its directors or administrators.  A foreign entity is deemed to be a CFC if:  - it is resident in a low-tax jurisdiction as defined in article 41H of the Income Tax Law; or  - a person resident of Chile has directly or indirectly a purchase option with respect to the foreign entity for 50% or more of its capital, profits or voting power."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","SUB","REGIME1",2019,"Section 8 paragraph 2 provides a so called motive test which allows the tax payer to prove that the company pursues an actual economic activity as far as the companies registered office is located in an EU-member State."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DOM","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","DEF","REGIME1",2019,"As of January 1, 2019, there are two CFC rules in Estonia:  1) CFC rule from the ATAD Directive applicable to companies; 2) CFC rule applicable to natural persons. In case of ATAD CFC rule, CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. In case of CFC rule applicable to natural persons, a legal person is deemed to be controlled by Estonian residents if one or several legal or natural persons who are Estonian residents own at least 50 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons.  The income of a foreign legal person is deemed to be the taxable income of a resident natural person if the condition prescribed above is fulfilled and the resident owns at least 10 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","DEF","REGIME1",2019,"The CFC rules requires, under some circumstances, the taxation in France, in the hands of a  French corporation, of the profits of a foreign entity which it owns.There are both control and low taxation threshold requirements : - a French corporation falls within the scope of CFC if it owns directly or indirectly more than 50 per cent of the share or voting rights of a foreign entity (company, subsidiary, branches, trust or comparable entities) ;  This threshold is reduced to 5% when more than 50% of the shares, shares, financial rights or voting rights of the legal entity established or incorporated outside France are held by companies established in France which act in concert, when the foreign entity is listed on a regulated market, or by companies that are directly or indirectly placed in a situation of control or dependence with respect to the legal person established in France and the foreign entity benefits from a preferential tax regime in the foreign State. An entity is considered to benefit from a preferential tax regime if it is not taxable in that State or taxable at a level that is less than 40% or more than it would have paid under the french law if it had been located in France (the threshold of 40 % aplies from the 1st of 2020, before that date the 50 % threshold aplies. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","DEF","REGIME1",2019,"A foreign company is a CFC when UK persons hold more than a 50% interest in that company, by reference to legal control, economic control, or accounting standards. A separate test applies to joint ventures."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","SUB","REGIME1",2019,"A foreign person is not deemed a CFC if there is real economic substance (i.e. adequate personnel, equipment, assets, and location to effectively carry out business activities) attributable to that person.  This condition is deemed to be fulfilled where the income from specified activities pursued with the entity’s/PE’s own assets and employees amount to at least 50% of its total income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","SUB","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","SUB","REGIME1",2019,"Yes, we have the Economic Activity Tests."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LBR","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","SUB","REGIME1",2019,"The CFC rule in the CIT Law applies only in case of CFC&rsquo;s income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company&#39;s income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","EXE","REGIME1",2019,"See question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","DEF","REGIME1",2019,"CFC is a non-domiciled entity that fulfils the following conditions:(i) It is treated as opaque. It is considered that companies, trusts, investment funds and partnerships always comply with this requirement. (ii) It is incorporated or established in a: non-cooperative or low-tax jurisdiction, or jurisdiction in which its passive income is not subject to an income tax, or jurisdiction in which the tax effectively paid for the entity's passive income is equal or less than 75% of the Peruvian tax which would be payable on the same income. (iii) Peruvian domiciled taxpayer alone or together with its Peruvian domiciled related parties owns directly or indirectly more than 50% of the capital, voting power or the profits of the entity. Options to acquire shares must be considered to determine the test control."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","YEAR","REGIME1",2019,"2013"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","EXE","REGIME1",2019,"The CFC Portuguese rule is not applicable to non-resident companies of other EU member states or EEA member states. In this last case, the exemption operates only if the member state complies with administrative tax cooperation similar to the one of the EU and the taxpayer demonstrates that his company is submitted to valid substantive economic reasons and develops agricultural, industrial, commercial or services economic activities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SGP","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VGB","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","SUB","REGIME1",2019,"One of the situations that, concurrently with others (see question 4), shall take place in order to apply CFC rules is that the non resident entity does not have the material and human resources to perform its activity or its passive income are at less 50% of the entity profits, or its profits result on deductible expenses for related parties in Argentina. Therefore, if this conditions are not meet the CFC rules are not applied."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","YEAR","REGIME1",2019,"1990"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","YEAR","REGIME1",2019,"2017"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHE","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","YEAR","REGIME1",2019,"1984 new regime introduced in 2013"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","SUB","REGIME1",2019,"(Yes) Controlled foreign company rule (implementation of ATAD 1 from 2019)  This point shall not apply where the controlled foreign company carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KAZ","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","EXE","REGIME1",2019,"CFC rules do not apply in the case of a company whose actually accrued annual income is 200 million won or less."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","YEAR","REGIME1",2019,"Entry into force on 13. July 2018 and applicable for taxable periods starting 1. January 2019."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LKA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","EXE","REGIME1",2019,"CFC rules are not applied if (except for the CFC, registered or otherwise organised in the target territory (blacklisted jurisdictions)):- passive income of the CFC does not exceed 1/3 of total income of this CFC during the tax period; or- actual corporate income tax paid on income of the CFC following the rules on corporate income tax or equivalent tax applied in this foreign state is not lower than 50 % of actual corporate income tax on income of CFC which would have been computed following the Lithuanian CFC rules."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","EXE","REGIME1",2019,"The rules do not apply to a CFC that has profits that do not exceed €750,000 or do not exceed 10% of its operation costs in the period."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","EXE","REGIME1",2019,"The CFC rule in the CIT Law is not applicable to an entity or permanent establishment with accounting profits of no more than EUR 750 000, and non-trading income of no more than EUR 75 000. However, this exclusion is not applicable for entity set or established in a low tax or no tax countries and territories."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MKD","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","YEAR","REGIME1",2019,"2006"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","YEAR","REGIME1",2019,"1976"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","SUB","REGIME1",2019,"The Danish rules are not subject to any substance test."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRO","A","CFC","REGIME1",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","DEF","REGIME1",2019,"Controlled foreign company rule (implementation of ATAD 1 from 2019)  Croatian Tax Administration shall treat an entity, or a permanent establishment of which the profits are not subject to tax or are exempt from tax in other Member State of the EU, as a controlled foreign company where the following conditions are met: (a) in the case of an entity, the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity;"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","EXE","REGIME1",2019,"n/a"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MAR","A","CFC","REGIME1",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","YEAR","REGIME1",2019,"1992"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","DEF","REGIME1",2019,"An entity shall be treated as a controlled foreign company if the following conditions are cumulatively met: a) the taxpayer, alone or together with its associated enterprises, holds a direct or indirect holding of more than 50% of the voting rights or directly or indirectly owns more than 50% of the capital of the entity or is entitled to receive more than 50% of that entity&#39;s profits; b) the tax on profits actually paid for its profits by the entity or permanent establishment is less than the difference between the profit tax that would have been levied from the entity or the permanent establishment, calculated in accordance with the provisions regarding to the tax on profit from Fiscal Code of this Title and the profit tax actually paid for its profits by the entity or by the permanent establishment. For the purposes of this letter, the permanent establishment of an entity treated as a foreign controlled company shall not be taken into account in so far as the head office is not subject to taxation or is exempt from tax in the jurisdiction of the controlled foreign company."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","YEAR","REGIME1",2019,"1962, 2017"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","YEAR","REGIME1",2019,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","DEF","REGIME1",2019,"There are three types of CFC: branch, controlled and affiliated. - In the controlled type, the controller has the right to make corporate decisions and to choose the majority of the management team.  - In the affiliated type, the controller has a significant influence in such decisions. Significant influence means the right to take part in the decisions concerning financial or operational policies. A controller that holds 20% or more of the voting capital of a company is deemed to have significant influence on this company."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHN","A","YEAR","REGIME1",2019,"2008"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CPV","A","CFC","REGIME1",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EGY","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","YEAR","REGIME1",2019,"2014"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRL","A","CFC","REGIME1",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","EXE","REGIME1",2019,"The CFC rules will not apply where the arrangements under which SPFs are performed have been entered into on an arm's length basis or are subject to Ireland's Transfer Pricing regime. There are exemptions for CFCs with low accounting profits or a low profit margin. An 'effective tax rate' exemption can apply where the tax paid by the CFC in its jurisdiction is greater than the difference between the tax it pays in its territory and the tax it would have paid in the State. A one-year grace period is also allowed in respect of newly-acquired CFCs where certain conditions apply. Relief is also available on certain distributions and on certain disposals of shares or securities in a CFC. In order to prevent double taxation, a credit will be available for any tax paid by the CFC arising in its jurisdiction or any other jurisdiction (including Ireland) on the chargeable income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","DEF","REGIME1",2019,"A CFC is a non-resident company, fund, institution or other entity in a low-tax country that is at least 50% owned or controlled, directly or indirectly, by resident taxpayers."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MDV","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","SUB","REGIME1",2019,"substantive economic activity supported by staff, equipment, assets and premises"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SEN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","EXE","REGIME1",2019,"Under the general rule, the income of a controlled foreign entity is deemed to be subject to low taxation if it is not taxed at all or is subject to tax that is lower than 12,1% (55% of the Swedish tax rate of 22%. for income year 2018). However, income is not considered to be subject to low taxation if the foreign legal entity is a tax resident, and liable to income tax, in one of the countries listed in a white list\u009d, provided that the income in question has not been expressly excluded in the list. In addition, the CFC regime does not apply to income derived from a foreign legal entity engaged in international shipping activities, provided that also the shareholder is engaged in shipping activities, whether directly or indirectly through a legal person resident in the EEA."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","EXE","REGIME1",2019,"Key exemptions, exclusions and relief measures include the following: a) residents who together with connected parties hold less than 10% of the participation and voting rights b)a high tax exemption where the taxes payable in a foreign jurisdiction at least equal 75% of the South African taxes which would have payable had the foreign resident been a South African resident. c) certain companies falling under the headquarter company rules. d) income or taxable income which is already taxed in South Africa. e) relief from foreign taxes paid by the CFC."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARE","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","EXE","REGIME1",2019,"No limitation in function of the size of the participation. No foreign tax credit. But when the CFC distributes profits that have already been subject to tax at the level of the Belgian corporate shareholder, based on the Belgian CFC-rules, these profits shall be fully deducted from the recipient's tax base."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","SUB","REGIME1",2019,"There is no substantial activity carve out."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","SUB","REGIME1",2019,"CFC regime use a substance analysis only for certain categories of income if the CFC carries on an active business as described in question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HTI","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","DEF","REGIME1",2019,"Greater than 50% of direct or indirect ownership in ordinary shares, voting rights or right to demand distributions. De facto control relationship."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","DEF","REGIME1",2019,"1) CFC rule from the EU Council Directive 2016/1164 (ATAD) applicable to companies; 2) CFC rule applicable to natural persons.The CFC rule in the CIT Law (Article 6) provides the definition of non-genuine arrangements, participation threshold, and limitation to apply CFC rule. The CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. CFC rule applies only in case of CFC&rsquo;s income arising from non-genuine arrangements that have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company&#39;s income. The CFC rule in the PIT Law (effective starting from 2013) is applicable to natural persons (article 17) of the law in Personal income Tax)  if at least 25% of a non-resident capital company (the stocks of which are not quoted in the regulated market of a European Union Member State or European Economic Area State), partnership or other legal person, a foreign foundation, trust or other legal entity set or established low tax or no tax countries and territories is owned or controlled, directly or indirectly, by resident taxpayers (individuals).  In this case profits of such company, partnership, person, foundation, trust or entity, whether distributed or not, are attributed proportionately to their resident shareholders and taxed accordingly (under individual income tax). The list of low tax or no tax countries and territories is established by the Cabinet of Ministers (Paragraph 1 of the Regulations of the Cabinet of Ministers dated of November 7, 2017 (No.655)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","YEAR","REGIME1",2019,"2013 - for natural persons. 2019 - for companies"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MCO","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","DEF","REGIME1",2019,">Portuguese definition of CFC (see article 66, CITC): Profits or incomes of non-residents in Portugal and submitted to clearly more favourable tax regime are treated (with appropriate deductions) as profits or incomes of companies with residence in Portugal that, directly or indirectly, have at least 25% of capital, voting rights, rights on profits or incomes or rights on assets of said non-residents companies. A non-resident company is considered submitted to a clearly more favourable tax regime if the residence jurisdiction is by law considered has such or if that company pays an effective CIT or equivalent lower than 50% of the Portuguese one."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","SUB","REGIME1",2019,"Portuguese CFC rule is excluded if CFC undertakes substantial activities (agriculture or industry or, not predominantly in Portugal, commerce or services), being such activities the cause of at least 75% of his profits or incomes, and if in the CFC main activity are not included some well described operations, as credit, financial, insurance, holding and lease of goods ones with personnel, equipment, actives and installations."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","DEF","REGIME1",2019,"CFC rules will generally apply if: taxpayer directly or indirectly holds more than 50% of capital or voting rights or an entitlement to the profits of a foreign entity, which is not subject to tax under CITA and foreign entity's tax paid is less than 50% of the tax that would have been paid under Slovenian CITA."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","SUB","REGIME1",2019,"Exceptions are determined for CFC that carries on a substantive economic activity and in cases, where one third or less of the income accruing to the CFC falls within the determined categories of income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","THA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AGO","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARM","A","CFC","REGIME1",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ATG","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","EXE","REGIME1",2019,"Certain exemptions provided for non-portfolio dividends (10% or more); 1) sale of a CFC interest. Further, where CFCs are located in a listed country (US, UK, Canada, France, Germany, NZ, Japan) only particular types of income (referred to as Eligible Designated Concession Income) is attributable to the Australian controller. 2) There is also an AFI subsidiary exemption which enables interest and certain asset and currency transactions to be exempt for CFCs that are subsidiaries of a registered Australian AFI (may be broader than Australian banks)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","SUB","REGIME1",2019,"Yes - active income test (less than 5% of income is from passive income, tainted sales, tainted services). Generally, if the CFC satisfies the 'active income test' then there is no need to attribute income from that CFC to its Australian controllers."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","SUB","REGIME1",2019,"No."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","EXE","REGIME1",2019,"CFC rules do not apply if:  - the passive income is less than 10% of the total profits;  - the value of the assets of the CFC that may generate passive income do not exceed 20% of the total value of its assets; or  - the passive income of the CFC was subject to income tax at an effective rate of at least 30% in the CFC jurisdiction."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COK","A","CFC","REGIME1",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","YEAR","REGIME1",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","DEF","REGIME1",2019,"Applies a definition of CFC that also covers certain transparent entities and PEs.  A CFC is a foreign entity that is at least 50% owned by an Indonesian taxpayer or at least 50% collectively owned by Indonesian taxpayers.  The ownership threshold that is used to determine the CFC status is the ownership percentage at the end of the Indonesian taxpayer’s fiscal year, which is based on either the percentage of paid-up capital or the percentage of paid-up capital with voting rights.  CFC is a non-listed foreign entity"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","YEAR","REGIME1",2019,"2003"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","YEAR","REGIME1",2019,"1978"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","DEF","REGIME1",2019,"A CFC is a foreign entity or foreign permanent establishment, the income of which is not taxable or is exempt in Luxembourg. In the case of a foreign entity, there must be a Luxembourg resident (either alone or with associated enterprises) that directly or indirectly holds more that 50% of the voting rights or capital, or is entitled to more that 50% of the profits. In addition, the income tax paid by the foreign entity or foreign permanent establishment must be lower than the income tax it would have paid on those profits if it were subject to tax in Luxembourg."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","DEF","REGIME1",2019,"Control (>50%)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","SUB","REGIME1",2019,"The rules contain a substance exclusion as from 1.1.2008, to be in line with the ECJs Cadbury judgment. This exemption from the general rule applies to income from a foreign legal entity that is resident within the European Economic Area (EEA), if the shareholder can prove that the foreign entity is established in the other country for business reasons and is engaged in real economic activities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TCA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","EXE","REGIME1",2019,"The United States has two sets of CFC inclusion rules.  A U.S. shareholder must include in income their share of the subpart F income (generally, passive/mobile income) of a CFC.  The subpart F income rules include a </span><span class=csF52F8E4D>de minimis rule - income that would otherwise be subpart F income is not treated as subpart F income if it is less than the lesser of 5% of the CFC&rsquo;s gross income or USD $1,000,000.  However, all of a CFC&rsquo;s income will be treated as subpart F income if the CFC&rsquo;s subpart F income and insurance income exceeds 70% of the CFC&rsquo;s gross income.  The subpart F income rules also include a high tax exception &ndash; subpart F income that is subject to an effective rate of income tax imposed by a foreign country greater than 90% of the maximum rate of U.S. tax imposed on corporations (currently, greater than 18.9%).  The second set of rules (adopted in 2017) requires a U.S. shareholder to include in income their global intangible low-taxed income (GILTI).  The GILTI rules apply a formulaic approach which generally requires an income inclusion by the U.S. shareholder based on their share of the income of their CFCs after excluding a 10% return on tangible assets of the CFCs from the GILTI amount.  Such income also excludes income that is effectively connected to a trade or business in the United States (which is taxed separately), subpart F income, related-party dividends, foreign oil and gas extraction income, or income that would be subpart F but is excluded by the high-tax exception.  Proposed rules would expand, pursuant to an election, the GILTI regime&rsquo;s exclusion for high-taxed income to high taxed income that would not otherwise qualify as subpart F income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","SUB","REGIME1",2019,"The United States CFC rules do not have a general substance requirement that would provide an exemption/exclusion to the CFC. But see response to question 7 for significant CFC exceptions/exclusions."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","SUB","REGIME1",2019,"Yes. There are provisions relating to foreign business establishments which result in net income being excluded for substantive businesses such as: a) a suitably equipped and staffed fixed base of business located outside South Africa solely or mainly for a purpose other than tax. b) a construction site lasting for at least 6 months. c) agricultural land used for bone fide farming activities. d) ships, vehicles, rolling stock and aircraft operated by the CFC or group company in a particular country."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AIA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","DEF","REGIME1",2019,"A CFC is a foreign resident company where a control test is satisfied (see below). First criteria: whether the CFC is a resident of a listed (Canada, France, Germany, Japan, NZ, UK, US) or unlisted country (all other countries). Second criteria: one of the three control tests must be satisfied. In particular: - Strict control: a group of five or fewer Australian 1 per cent entities and their associates hold at least 50 per cent (direct and indirect interests) of the foreign company. - Assumed control: a foreign company owns or is entitled to acquire an associate-inclusive control interest of at least 40 per cent in the foreign company. - De facto control: a group of five or fewer Australian entities, either alone or with associates, effectively controls the foreign company."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BHR","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","SUB","REGIME1",2019,"There are no general exemptions based on whether the CFC is undertaking substantial activities. However, there are substance-based exceptions from certain specific rules in Canada&#39;s CFC regime that otherwise include a CFC&#39;s active business income in its CFC income. Very generally, if a CFC carries on an active business the principal purpose of which is to earn income that is of a type that is generally passive in nature (e.g., interest or royalty income), then the income is subject to the CFC rule, unless among other requirements the CFC carries on the business principally with arm&#39;s length persons and it employs more than five full-time employees in the active conduct of the business. There are also exceptions from the &quot;base erosion&quot; rules, which exceptions generally apply where more than 90 percent of the CFC&#39;s gross revenues from the specific activity to which a given base erosion rule applies (e.g., the lending of money to Canadian residents) derives from transactions with arm&#39;s length non-residents."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHN","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","YEAR","REGIME1",2019,"CFC rules were first introduced in December, 2016, applicable as of January 1st, 2017."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","EXE","REGIME1",2019,"Controlled foreign company rule (implementation of ATAD 1 from 2019)  ETR 50% compared with Croatia : the actual corporate tax paid on its profits by the entity or permanent establishment is lower than the difference between the corporate tax that would have been charged on the entity or permanent establishment under the applicable corporate tax system in the Croatia of the taxpayer and the actual corporate tax paid on its profits by the entity or permanent establishment."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JEY","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","DEF","REGIME1",2019,"To be a CFC the Korean rules require: 1. With respect to a foreign company, 50% or more of whose voting shares are directly or indirectly held by a Korean resident along with his/her/its specially-related persons, including relatives. The Korean resident holding directly or indirectly 10% or more of shares in such company(including the direct holdings by the specially-related persons) is subject to CFC rules. 2. The foreign company is located in a significantly low tax jurisdiction with an average effective tax rate of 15% or less on taxable income for the past three years."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","SUB","REGIME1",2019,"n/a"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","SUB","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","EXE","REGIME1",2019,"list of low tax jurisdictions"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","YEAR","REGIME1",2019,"2007"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","DEF","REGIME1",2019,"Control criteria: 1. There is deemed to be Norwegian control of a foreign company or undertaking if no less than one half of the ownership interests or capital of such company or undertaking are directly or indirectly owned or controlled by Norwegian taxpayers, at both the beginning and the end of the tax year. 2. There is also Norwegian control if the company or the undertaking were deemed to be Norwegian-controlled in the year before the tax year, unless less than one half of the ownership interests or capital are directly or indirectly controlled by Norwegian taxpayers, at both the beginning and the end of the tax year. 3. If Norwegian taxpayers own or control more than 60 percent of the ownership interests or capital as at the end of the tax year, there is Norwegian control irrespective of 1 and 2. Correspondingly, there is not Norwegian control if Norwegian taxpayers own or control less than 40 percent of the ownership interests or capital as at the end of the tax year.  Low-tax jurisdictions: Low-tax jurisdictions are jurisdictions in which the ordinary income tax on the overall profit of the company or undertaking is less than two thirds of the tax that would have been levied on such company or undertaking if it had been resident in Norway. The Norwegian tax rate in 2018 is 23 pct."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAK","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","SUB","REGIME1",2019,"No, see answer in question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZMB","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BMU","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","EXE","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COD","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","EXE","REGIME1",2019,"For mixed income, the following rule is provided: Section 9 - Tax threshold for mixed income When applying section 7 (1), income with respect to which a foreign company is an intermediate company is not taken into account if the gross proceeds underlying it amounts to no more than 10 percent of the company's total gross proceeds, provided that the amounts not taken into account for a company or a taxpayer under this provision do not exceed a total of €80,000."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","YEAR","REGIME1",2019,"1972"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DJI","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","EXE","REGIME1",2019,"An entity would not be treat as a controlled foreign company if the amount of the income that falls within CFC rules is lower than the 15 percent of the total amount of incomes."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","SUB","REGIME1",2019,"CFCs which carry on a substantive economic activity supported by staff, equipment, assets and premises. For CFCs located in a non-EEA state, it is also required that Finland and the country in which the CFC is located have agreed on adequate exchange of information and that the CFC is engaged with production activity. The exclusion does not apply to CFCs located in a jurisdiction included in the EU list of non-cooperative jurisdictions for tax purposes."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","EXE","REGIME1",2019,"CFC rules, in principle, are not applicable with respect of foreign branches or subsidiaries located in another EU country. However, this exception is not applicable if the French tax authorities can demonstrate that the foreign entity located in another EU country constitutes an artificial arrangement, set up to circumvent French tax legislation. This concept is similar to the ‘abuse of law’ concept, although it does not have all the same characteristics."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","YEAR","REGIME1",2019,"1980"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","DEF","REGIME1",2019,"A CFC is a legal person or entity which is resident for tax purposes in another country if the following conditions are met cumulatively: a) if the taxpayer alone or jointly with the associated persons directly or indirectly holds shares, stakes, voting rights or participations in the capital exceeding fifty percent (50%) or is entitled to over fifty percent (50%) of the profit of that legal person or entity, b) if the above legal person or entity is subject to taxation in a non-cooperating state or a country with a preferential tax regime, i.e. a special regime allowing for a substantially lower taxation level than that under the general regime, c) if more than thirty percent (30%) of net income before tax realized by the legal person or entity falls into one or more certain categories defined in the very same article, d) the legal person or entity is not a company of which the main class of shares of which are traded on a regulated market."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","DEF","REGIME1",2019,"Applies a definition of CFC that also covers certain transparent entities and Pes.  Applies a legal and economic control test for defining a CFC : controls more than half of its voting rights or its subscribed capital, directly or indirectly, or is entitled to more than half of its after-tax profit"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KAZ","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MAC","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","SUB","REGIME1",2019,"Malta has opted for Sub-paragraph 2(b) of Article 7 of EU Council Directive 2016/1164. This targets any non-distributed income which arises from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SRB","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","DEF","REGIME1",2019,"The CFC rules apply to resident companies and individuals, as well as any non-resident with a PE in Sweden, with an direct or indirect 25 % holding or control, by the taxpayer alone or together with associated persons, of capital or voting power in a foreign legal entity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VCT","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","EXE","REGIME1",2019,"CFC law standards are not applied:  A) When the entity resident in the other country is, according to Argentine rules, a permanent establishment (PE) in that other country. In that case the specific Argentine rules for PE located outside Argentina shall be applied.  B) When the Argentine entity is a financial entity according to the Argentine Law of Financial Entities (Law 21526).  C) When the Argentine entity is an insurance company according to the Argentine Law of Insurance Companies and Insurance Company’s Control (Law 20091).  D) When the Argentine entity is a trust/common fund and investment company according to the Argentine Law of Trust/Common Fund and Investment Company (Law 24083).  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BFA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","YEAR","REGIME1",2019,"2014"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","SUB","REGIME1",2019,"As of January 1, 2019, there are two CFC rules in Estonia:  1) CFC rule from the ATAD Directive applicable to companies; 2) CFC rule applicable to natural persons. ATAD CFC rule applies only in case of CFC’s income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company's income.  In case of CFC rule applicable to natural persons, there is an exemption for a CFC if more than 50 per cent of its annual income is derived from actual economic activity or if the state or territory of location of the legal person provides the Estonian tax authority with information concerning the income of a person controlled by Estonian residents."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","EXE","REGIME1",2019,"Effective tax rate that does not exceed 15%"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JAM","A","CFC","REGIME1",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","EXE","REGIME1",2019,"1 Exemption for the full inclusion (1) Specified CFCs (i.e. Cash Box, Paper Company and Black-List Company) : effective tax rate of a CFC greater than or equal to 30% (2) Other CFCs : effective tax rate of a CFC greater than or equal to 20% 2 Exemption for the passive income inclusion (1) Effective tax rate of a CFC greater than or equal to 20% (2) Either passive income less than or equal to JPY 20 million, or passive income per profits before tax ratio less than or equal to 5%"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","EXE","REGIME1",2019,"As the main rule of the Mexican CFC legislation, the CFC's income needs to be subject to an income tax that is equivalent to at least 75% of the income tax that would have been paid in Mexico. Income taxed at a statutory rate of at least 22.5%, provided that all income is taxable, except dividends paid between entities that are residents of the same jurisdiction and that their deductions have been actually incurred. Royalties received by foreign entities for the use or concession of use of a patent or industrial secrets, provided that some conditions are met. Our control test is set as an exclusion (see question 4). Income derived from restructuring operations, under certain conditions. Mexican authorities can authorize Mexican residents not to apply CFC legislation if the controlled entity has authorization to act as a financial institution in the country it resides."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","SUB","REGIME1",2019,"The regime is not applicable if the foreign entity carries out active business activities, unless their passive income is greater than 20% of their total income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","DEF","REGIME1",2019,"The CFC rule has been introduced in Mauritius in Section 90A of the Income Tax Act 1995 with effect from 01 July 2019 as an anti-avoidance provision. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","EXE","REGIME1",2019,"Australian companies not subject to the CFC regime."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","YEAR","REGIME1",2019,"1989"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SYC","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BWA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","DEF","REGIME1",2019,"CFCs are those entities that: Are controlled by one or more Colombian tax residents, according to the terms in the new legislation, (an entity is controlled if it is a related party due to the presumptions of subordination contemplated under transfer pricing rules). Do not have their tax residency in Colombia. CFCs include investment vehicles such as corporations, trusts, collective investment funds, other fiduciary businesses and private interest foundations, incorporated with operation or domiciled abroad, regardless if they are considered to be legal entities or not, or if they are disregarded for tax purposes or not. If the entity is established in a non-cooperative or low-tax jurisdiction, control is presumed regardless of the level of participation or involvement of the Colombian resident in the entity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","DEF","REGIME1",2019,"Control test : 50% basis"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","EXE","REGIME1",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","SUB","REGIME1",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","EXE","REGIME1",2019,"The situation in which the rules do not apply is when the CFC’s shares are listed on a recognised stock exchange."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","SUB","REGIME1",2019,"Ireland selected Option B in accordance with Article 7(2)(b), ATAD. The rules operate by attributing undistributed income of the CFCs, arising from non-genuine arrangements put in place for the essential purpose of avoiding tax, to the controlling company, or a connected company in Ireland, for taxation, where the controlling company or the connected company have been carrying out &tilde;significant people functions&quot;(SPFs) in Ireland"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","SUB","REGIME1",2019,"Yes. The CFC rules do not apply, if the controlled company (i) is resident in a treaty country and its income is not mainly financial income, or (ii) is resident in a country within the EEA and is engaged in business activities there and the Icelandic tax authorities are able to request all necessary information according to an international treaty."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","SUB","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","SUB","REGIME1",2019,"The Italian-resident taxpayer which controls the CFC could apply for a tax ruling claiming the non-application of the CFC rules. In case of non-UE resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that: - the CFC predominantly carries out, as its main business purpose, an industrial activity within the local market, i.e. within the market of the country where the company is located. The non-resident company must be economically and socially integrated in this market, and the presence of a real business organisation in such market is not enough (c. 51/E/2010). For banks, financial institutions and insurance companies, this evidence is deemed to be given if most of the funds, investments, and proceeds arise from the jurisdiction where these entities are located; or - alternatively, the participation in the CFC does not achieve the result of shifting income to low-tax jurisdictions. In case of EU resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that: - the CFC does not represent a wholly artificial arrangement aimed at obtaining an undue tax advantage (see at Cadbury-Schweppes decision by EUCJ)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NGA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","OMN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","SUB","REGIME1",2019,"The CFC rules do not apply where the CFC carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances (Article 7 paragraph 2 point a ATAD). The exemption is applicable to CFC located in an EU-Member State as well as for CFC located in a third country that is not party to the EEA Agreement."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DMA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","DEF","REGIME1",2019,"Under the Danish CFC legislation, a Danish resident parent company is liable to taxation of the income of a non-resident subsidiary or a foreign permanent establishment to the extent of its participation if: the Danish parent company directly or indirectly controls more than 50% of its voting power; more than 50% of the subsidiary's taxable income derives from CFC-income; and at least 10% of the subsidiary's assets are CFC-assets."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","DEF","REGIME1",2019,"The taxpayer by itself, or together with its associated enterprises holds a participation equal or more than 50 percent of capital, voting rights or outcome. Also the actual corporate tax paid on its profits by the entity is lower than a 75 percent of the corporate tax that would have been charged on the entity under the corporate tax system of Spain."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","EXE","REGIME1",2019,"As mentioned above (question 4) companies of which the main class of shares of which are traded on a regulated market are excluded (i.e. listed companies are excluded)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LCA","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","EXE","REGIME1",2019,"Malta has opted to implement the threshold exclusions set out in Sub-paragraph (4) of Article 7 of the EU Council Directive 2016/1164."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAK","A","YEAR","REGIME1",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SLE","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","UKR","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","DEF","REGIME1",2019,"CFC rules are applied to the following entities:  1) A trust located abroad as long as the Argentine resident manage its assets. As examples of the existence of this management can be mentioned:   a) When the trust is revocable trust.  b) When the trustor and the trust’s beneficiary are the same person.  c) When the Argentine resident has the right to directly invest or the assets of the trust.  2) An entity which is not considered taxpayer in the foreign country, that is to say, its profits are directly assigned to the Argentine resident.  3) An entity which is considered taxpayer in the foreign country, as long as some requirements take place concurrently. These requirements are:  a) The Argentine resident control, directly or directly, the entity located in the other country. b) The non resident entity does not have the material and human resources to perform its activity or its passive and portfolio income are equal or greater than 50% of the entity profits, or its profits result on deductible expenses for related parties in Argentina. c) The income or profits mentioned in b) are taxed at a rate below than 75% of the rate at which those income or profits would have been taxed in Argentina, or the entity in question is located in a non-cooperative or low or no tax jurisdiction or country.  In order to determiner the condition mentioned in a), i.e. if the Argentine resident controls the entity located in other country, one of these cases has to take place:  a) The Argentine resident, directly or indirectly, owns 50% or more of the foreign entity net worth or profits. b) The Argentine resident, directly or indirectly, has 50% or more of the votes for taking decisions in the foreign entity. c) The Argentine resident, directly or indirectly, has the right to manage and sell the entity goods and properties. d) The Argentine resident, direct or indirectly, has the votes to appoint the board of directors of the entity. e) The Argentine resident takes part in the board of directors and has in it the votes to impose decisions. f) The Argentine resident, directly or indirectly, has the votes to dismiss the CEO or managers of the entity. g) The Argentine resident has any right on the entity profits. h) At least 30% of the value of the entity assets arises from financial investments that generate passive income from Argentine source. i) Passive and portfolio income obtained by the entity is taxed at a rate below than 75% of the rate at which those income would have been taxed in Argentina.  As regards indirect control, it takes place when the Argentine resident controls the foreign entity (i.e. one of the facts listened above takes place) through one of these means:  a) An entity which is controlled by the Argentine resident. b) Argentine resident’s relative (e.g.: spouse). c) The person who cohabits with the Argentine resident.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","DEF","REGIME1",2019,"Definition of CFC:If the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity (Art. 7 paragraph 1 ATAD); and the actual corporate tax paid on its profits by the entity or permanent establishment does not surpass 12.5%."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BLZ","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","SUB","REGIME1",2019,"Yes, active income and dividends attributable to active income in the CFC are excluded."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","DEF","REGIME1",2019,"German taxpayers have to hold more than 50 percent of the foreign companies shares. Thereby the size of the participation of each single shareholder is irrelevant."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","SUB","REGIME1",2019,"There are two series of exemptions :  - Inside the EU, the foreign entity established in a member State will not be subject to the CFC rules, unless  the French tax authorities demonstrate that the foreign entity located in another EU country constitutes an artificial arrangement, set up to circumvent French tax legislation ;  -In other cases, if a French company falls within the scope of CFC, it can be exempted if it demonstrates that the operations of the entity established outside France are primarily intended to have an object and effect other than to transfer profits in a State or territory where it is subject to a preferential tax regime.This condition is deemed to be fulfilled when the entity established outside France has mainly an industrial or commercial activity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GEO","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GGY","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IMN","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","DEF","REGIME1",2019,"If a person resident in Italy (a legal entity, partnership, individual) holds, directly or indirectly, also through trust companies, the control of an enterprise, company or other entity, resident or located in States or Territories permitting privileged tax regimes, the income earned by the controlled foreign entity is imputed to the resident entity or person, as of the end of the fiscal year of the controlled foreign entity. The relevant control is based on the civil law, which is described in article 2359 Civil Code. Subsidiaries enterprises are: 1) companies in which another company has the majority of the votes that can be exercised in the general shareholders' meeting; 2) companies in which another company has sufficient votes to exercise a significant influence in the general shareholders' meeting; 3) companies that are under the significant influence of another company by virtue of particular contractual obligations with it 4). A tax regime is privileged where the nominal level of taxation is less than 50 percent of that applicable in Italy."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","SUB","REGIME1",2019,"CFC rules are not applied in cases when CFC (except for the CFC, registered or otherwise organised in the target territory (blacklisted jurisdictions)) has staff members and uses assets to ensure actual economic activities in the jurisdiction where this CFC is registered or otherwise organised."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","SUB","REGIME1",2019,"The Polish CFC rules do not apply to a non-resident company if the non-resident company is established and subject to tax on the worldwide income in a EU/EEA country, provided it meets the substantial genuine business activity test. When assessing whether a CFC carries out a genuine economic activity, the Polish CFC rules recommend paying particular notice to whether: (i) the registration of a CFC matches an actual establishment intended to carry on genuine economic activities, i.e. the company has local, qualified personnel and the requisite equipment; (ii) a CFC has been created as a structure functioning in isolation for economic reasons; (iii) the premises, personnel or equipment of a CFC are commensurate with the scope of its activities; (iv) arrangements concluded by the CFC are consistent with economic reality, have an economic justification, and are not manifestly contrary to the general economic interests of the company; and (v) a CFC independently performs its basic economic functions with the use of its own resources, including managers at the company’s location."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRY","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","SUB","REGIME1",2019,"The provisions of CFC rules shall not apply if the controlled foreign company has its fiscal residence or is located in a Member State / third country which is a party to the EEA Agreement and carries out a significant economic activity, supported by personnel, equipment, assets and spaces, as evidenced by the relevant facts and circumstances."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","RUS","A","YEAR","REGIME1",2019,"2015"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SAU","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","EXE","REGIME1",2019,"N/A"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","YEAR","REGIME1",2019,"2018, with effect in 2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","URY","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ABW","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BHS","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","EXE","REGIME1",2019,"Tax Rate Exemption : ETR 50% compared with Czech"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","EXE","REGIME1",2019,"As of January 1, 2019, there are two CFC rules in Estonia:  1) CFC rule from the ATAD Directive applicable to companies; 2) CFC rule applicable to natural persons. ATAD CFC rule is not applicable to an entity or permanent establishment with accounting profits of no more than EUR 750 000, and non-trading income of no more than EUR 75 000. In case of CFC rule applicable to natural persons, CFC's income is taxed in Estonia if CFC is located in a low tax rate territory. A low tax rate territory is a foreign state or a territory with an independent tax jurisdiction in a foreign state, which does not impose a tax on the profits earned or distributed by a legal person or where such tax is less than one-third of the income tax which a natural person who is an Estonian resident would have to pay on a similar amount of business income. There is a white list of the jurisdictions that are not considered to be a low tax rate territory. This list includes all Estonian tax treaty partners."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","EXE","REGIME1",2019,"Tax rate exemption - where the local tax paid is at least 75% of the tax that would have been paid in the UK. De minimis threshold - less than £50k profits in a 12 month period, or less than £500k profits so long as passive interest income does not exceed £50k in that period. Low profit margin exemption - where accounting profits are not more than 10% of relevant operating expenses. Excluded countries list based on regimes with similar tax rules to UK, subject to an anti-avoidance test and limits on passive income. Temporary exemption period for certain acquisitions, subject to anti-avoidance conditions. Partial and full exemption for certain types of intra-group finance profits, subject to detailed anti-avoidance conditions. Exemption for certain trading profits where a minority of significant people functions are carried out in the UK."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRD","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","YEAR","REGIME1",2019,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IND","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","YEAR","REGIME1",2019,"2019 (ATAD)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","YEAR","REGIME1",2019,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MSR","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","DEF","REGIME1",2019,"More than 50% owned by 5 or fewer residents,; or 40% or more owned by a single resident owner; or controlled by 5 or fewer residents. Usual aggregation and look through rules."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","YEAR","REGIME1",2019,"1988"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","SUB","REGIME1",2019,"The CFC rules do not have that kind of exemptions."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","RUS","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SMR","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TTO","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AND","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","YEAR","REGIME1",2019,"1999"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","EXE","REGIME1",2019,"There are exemptions for passive income that would otherwise be included in CFC income, which, in general terms, apply where a CFC’s passive income is closely linked to an active business of another non-resident corporation in which the Canadian taxpayer has a significant interest. In order to qualify for one of these exemptions, the link between the passive income and the active business must be one of those described in the CFC legislation (and meet additional legislated conditions). Notably, these include passive income of the CFC that is directly related to active business activities of the other corporation, and passive income that derives from certain payments (e.g., interest) that are deductible in computing the active business income of the other corporation."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CIV","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COG","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","SUB","REGIME1",2019,"There are exclusions based on substantial activities and reasonable reasons for establishing in a country."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","SUB","REGIME1",2019,"The UK rules in relation to trading profits operate by reference to where the significant people functions (SPFs) that generate those profits are carried out, rather than by applying a generic test in relation to substantial activities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","CFC","REGIME1",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","YEAR","REGIME1",2019,"2001"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","YEAR","REGIME1",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","DEF","REGIME1",2019,"A controlled foreign taxable subject (i.e. CFC) means: 1) a controlled foreign taxable entity; 2) a permanent establishment of a Lithuanian entity whose income is not attributable to the tax base of the Lithuanian entity.  A controlled foreign taxable entity means a foreign entity where a Lithuanian entity alone or together with associated persons on the last date of the tax period of this foreign entity directly or indirectly owns more than 50 % of shares (interests, member shares), voting rights or rights to the share of distributable profits or exclusive rights to purchase them.  The income of the CFC is taxed only if: 1) a CFC is registered or otherwise organised in the target territory (blacklisted jurisdiction); or 2) passive income of the CFC exceeds 1/3 of total income of this CFC during the tax period; and 3) actual corporate income tax paid on income of the CFC following the rules on corporate income tax or equivalent tax applied in this foreign state is lower than 50 % of actual corporate income tax on income of CFC which would have been computed following the Lithuanian CFC rules. For the purpose of this paragraph, CFC income includes only passive income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","DEF","REGIME1",2019,"CONTROL TEST: When the taxpayer has the effective control or control of the administration of the foreign entity (to the extent, that he can decide the moment of the distribution of income or dividends, either directly or through another person) by reason of an average participation per day in the foreign entity. As an anti-fragmentation rule, it is required to add up the average participation per day of related parties and closely-related-individuals regardless where they reside.  OTHER: It applies to foreign legal entities, transparent entities and any kind of arrangement. It does not apply to PEs held directly by the Mexican taxpayer, since the income of such PEs should be accrued by the Mexican taxpayer by reason of other chapters of the law."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MNG","A","CFC","REGIME1",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","EXE","REGIME1",2019,"There are the following CFC exemptions: 1.- The total passive income is equal or less than 20% of the total CFC´s income. 2.- The total passive income is equal or less than US$ 6,360 approximately (5 Tax Unit). 3.- Peruvian source income, except for the income generated by CFC as a result of transactions carried out with domiciled taxpayers in the country, provided that: (i) they are related parties, (ii) such income constitutes a deductible expense for the domiciled taxpayers, and (iii) such income constitutes Peruvian source income subjects to a Tax rate of less than 30%."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","DEF","REGIME1",2019,"In the case of the Polish CFC rules, in principle, control is not defined directly, but an indication of its meaning can be gleaned from the first (of three) conditions for constituting a CFC. The CFC rules refer to the 50 per cent control threshold and say that a Polish taxpayer controls a foreign company if he owns continuously for at least 30 days, directly or indirectly, at least (i) 50 per cent of the company’s capital (legal control); (ii) 50 per cent of the voting rights in the controlling or administrative organs of the company (legal control); or (iii) 50 per cent of the shares related to the right to participate in the company’s profits (economic control). Moreover, a foreign company whose tax residence is in one of the 26 tax havens is considered a CFC regardless of the level of control over this company, level of taxation of its profits, or type of income received by it (CFC presumption). The Polish CFC rules apply also to the foreign permanent establishment of a Polish taxpayer."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AIA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AIA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BHR","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BHR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","SUB","_Z",2019,"There are no general exemptions based on whether the CFC is undertaking substantial activities. However, there are substance-based exceptions from certain specific rules in Canada&#39;s CFC regime that otherwise include a CFC&#39;s active business income in its CFC income. Very generally, if a CFC carries on an active business the principal purpose of which is to earn income that is of a type that is generally passive in nature (e.g., interest or royalty income), then the income is subject to the CFC rule, unless among other requirements the CFC carries on the business principally with arm&#39;s length persons and it employs more than five full-time employees in the active conduct of the business. There are also exceptions from the &quot;base erosion&quot; rules, which exceptions generally apply where more than 90 percent of the CFC&#39;s gross revenues from the specific activity to which a given base erosion rule applies (e.g., the lending of money to Canadian residents) derives from transactions with arm&#39;s length non-residents."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHN","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHN","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","YEAR","_Z",2019,"CFC rules were first introduced in December, 2016, applicable as of January 1st, 2017."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","YEAR","_Z",2024,"CFC rules were first introduced in December, 2016, applicable as of January 1st, 2017."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","EXE","_Z",2019,"CFC rules, in principle, are not applicable with respect of foreign branches or subsidiaries located in another EU country. However, this exception is not applicable if the French tax authorities can demonstrate that the foreign entity located in another EU country constitutes an artificial arrangement, set up to circumvent French tax legislation. This concept is similar to the ‘abuse of law’ concept, although it does not have all the same characteristics."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","EXE","_Z",2024,"There are two series of exemptions :                                               - Inside the EU, the foreign entity established in a member State will not be subject to the CFC rules, unless  the French tax authorities demonstrate that the foreign entity located in another EU country constitutes an artificial arrangement, set up to circumvent French tax legislation ;                                                   - In other cases, if a French company falls within the scope of CFC, it can be exempt if it demonstrates that the operations of the entity established outside France are primarily intended to have an object and effect other than to transfer profits in a State or territory where it is subject to a preferential tax regime.                         This condition is deemed to be fulfilled when the entity established outside France has mainly an industrial or commercial activity.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","DEF","_Z",2019,"A CFC is a legal person or entity which is resident for tax purposes in another country if the following conditions are met cumulatively: a) if the taxpayer alone or jointly with the associated persons directly or indirectly holds shares, stakes, voting rights or participations in the capital exceeding fifty percent (50%) or is entitled to over fifty percent (50%) of the profit of that legal person or entity, b) if the above legal person or entity is subject to taxation in a non-cooperating state or a country with a preferential tax regime, i.e. a special regime allowing for a substantially lower taxation level than that under the general regime, c) if more than thirty percent (30%) of net income before tax realized by the legal person or entity falls into one or more certain categories defined in the very same article, d) the legal person or entity is not a company of which the main class of shares of which are traded on a regulated market."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","DEF","_Z",2024,"According to par.1 of article 66 of Income Tax Code (ITC), a CFC is a foreign legal person, or foreign legal entity, or a foreign permanent establishment of which the profits are not subject to tax or are exempt from tax, if the following conditions are met cumulatively: \na) in the case of an entity, the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity; and\nb) the actual corporate tax paid on its profits by the entity or permanent establishment is lower than the difference between the corporate tax that would have been charged on the entity or permanent establishment under the Greek corporate tax system of the taxpayer that would be due by such person in Greece and the actual corporate tax paid on its profits by the entity or permanent establishment; and\nc) if more than thirty percent (30%) of net income before tax realized by the legal person or legal entity falls into one or more certain categories as defined in paragraph 3 of the same article (ITC). \n\nA CFC is a legal person or entity which is resident for tax purposes in another country if the following conditions are met cumulatively:    a) if the taxpayer alone or jointly with the associated persons directly or indirectly holds shares, stakes, voting rights or participations in the capital exceeding fifty percent (50%) or is entitled to over fifty percent (50%) of the profit of that legal person or entity,    b) if the above legal person or entity is subject to taxation in a non-cooperating state or a country with a preferential tax regime, i.e. a special regime allowing for a substantially lower taxation level than that under the general regime,    c) if more than thirty percent (30%) of net income before tax realized by the legal person or entity falls into one or more certain categories defined in the very same article,    d) the legal person or entity is not a company of which the main class of shares of which are traded on a regulated market."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRL","A","YEAR","_Z",2024,"2008"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","EXE","_Z",2024,"The Italian-resident taxpayer which controls the CFC could apply for a tax ruling claiming the non-application of the CFC rules. In case of non-UE resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that:    - the CFC predominantly carries out, as its main business purpose, an industrial activity within the local market, i.e. within the market of the country where the company is located. The non-resident company must be economically and socially integrated in this market, and the presence of a real business organisation in such market is not enough (c. 51/E/2010). For banks, financial institutions and insurance companies, this evidence is deemed to be given if most of the funds, investments, and proceeds arise from the jurisdiction where these entities are located; or    - alternatively, the participation in the CFC does not achieve the result of shifting income to low-tax jurisdictions. In case of EU resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that: - the CFC does not represent a wholly artificial arrangement aimed at obtaining an undue tax advantage (see at Cadbury-Schweppes decision by EUCJ)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","DEF","_Z",2019,"To be a CFC the Korean rules require: 1. With respect to a foreign company, 50% or more of whose voting shares are directly or indirectly held by a Korean resident along with his/her/its specially-related persons, including relatives. The Korean resident holding directly or indirectly 10% or more of shares in such company(including the direct holdings by the specially-related persons) is subject to CFC rules. 2. The foreign company is located in a significantly low tax jurisdiction with an average effective tax rate of 15% or less on taxable income for the past three years."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","DEF","_Z",2024,"To be a CFC the Korean rules require:    1. With respect to a foreign company, 50% or more of whose voting shares are directly or indirectly held by a Korean resident along with his/her/its specially-related persons, including relatives. The Korean resident holding directly or indirectly 10% or more of shares in such company(including the direct holdings by the specially-related persons) is subject to CFC rules.    2. The foreign company is located in a significantly low tax jurisdiction with an average effective tax rate of 15% or less on taxable income for the past three years."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","SUB","_Z",2019,"n/a"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","SUB","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","SUB","_Z",2024,"The Luxembourg resident (either alone or with associated enterprises) should include in its taxable basis the non-distributed income of the foreign entity or foreign permanent establishment that result from non-genuine arrangements that have been put in place for the essential purpose of obtaining a tax advantage. Non-genuine arrangements mean arrangements where the CFC would not own the assets or would not undertake the risks to generate all or part of the income, if it was not controlled by the Luxembourg resident. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","YEAR","_Z",2019,"2007"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","YEAR","_Z",2024,"2007"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAK","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAK","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","SUB","_Z",2019,"No, see answer in question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","SUB","_Z",2024,"N/A"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZMB","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZMB","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","UZB","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","DEF","_Z",2019,"A CFC is a foreign resident company where a control test is satisfied (see below). First criteria: whether the CFC is a resident of a listed (Canada, France, Germany, Japan, NZ, UK, US) or unlisted country (all other countries). Second criteria: one of the three control tests must be satisfied. In particular: - Strict control: a group of five or fewer Australian 1 per cent entities and their associates hold at least 50 per cent (direct and indirect interests) of the foreign company. - Assumed control: a foreign company owns or is entitled to acquire an associate-inclusive control interest of at least 40 per cent in the foreign company. - De facto control: a group of five or fewer Australian entities, either alone or with associates, effectively controls the foreign company."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","DEF","_Z",2024,"A CFC is a foreign resident company where a control test is satisfied (see below). \nFirst criteria: whether the CFC is a resident of a listed (Canada, France, Germany, Japan, NZ, UK, US) or unlisted country (all other countries). \nSecond criteria: one of the three control tests must be satisfied. In particular: \n- Strict control: a group of five or fewer Australian 1 per cent entities and their associates hold at least 50 per cent (direct and indirect interests) of the foreign company. \n- Assumed control: a foreign company owns or is entitled to acquire an associate-inclusive control interest of at least 40 per cent in the foreign company. \n- De facto control: a group of five or fewer Australian entities, either alone or with associates, effectively controls the foreign company.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BMU","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BMU","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","EXE","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","EXE","_Z",2024,"No."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COD","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COD","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","YEAR","_Z",2019,"1972"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","YEAR","_Z",2024,"1972"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","EXE","_Z",2019,"An entity would not be treat as a controlled foreign company if the amount of the income that falls within CFC rules is lower than the 15 percent of the total amount of incomes."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","EXE","_Z",2024,"There are exclusions based on substantial activities and reasonable reasons for establishing in a country."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","SUB","_Z",2019,"As of January 1, 2019, there are two CFC rules in Estonia:  1) CFC rule from the ATAD Directive applicable to companies; 2) CFC rule applicable to natural persons. ATAD CFC rule applies only in case of CFC’s income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company's income.  In case of CFC rule applicable to natural persons, there is an exemption for a CFC if more than 50 per cent of its annual income is derived from actual economic activity or if the state or territory of location of the legal person provides the Estonian tax authority with information concerning the income of a person controlled by Estonian residents."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","SUB","_Z",2019,"CFCs which carry on a substantive economic activity supported by staff, equipment, assets and premises. For CFCs located in a non-EEA state, it is also required that Finland and the country in which the CFC is located have agreed on adequate exchange of information and that the CFC is engaged with production activity. The exclusion does not apply to CFCs located in a jurisdiction included in the EU list of non-cooperative jurisdictions for tax purposes."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","YEAR","_Z",2019,"1980"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","YEAR","_Z",2024,"1980"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","EXE","_Z",2019,"Controlled foreign company rule (implementation of ATAD 1 from 2019)  ETR 50% compared with Croatia : the actual corporate tax paid on its profits by the entity or permanent establishment is lower than the difference between the corporate tax that would have been charged on the entity or permanent establishment under the applicable corporate tax system in the Croatia of the taxpayer and the actual corporate tax paid on its profits by the entity or permanent establishment."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","EXE","_Z",2024,"(Yes) Controlled foreign company rule (implementation of ATAD 1 from 2019)        This point shall not apply where the controlled foreign company carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JEY","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JEY","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KAZ","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KAZ","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","SUB","_Z",2019,"Malta has opted for Sub-paragraph 2(b) of Article 7 of EU Council Directive 2016/1164. This targets any non-distributed income which arises from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SRB","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SRB","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","EXE","_Z",2024,"Exceptions are determined for CFC that carries on a substantive economic activity and in cases, where one third or less of the income accruing to the CFC falls within the determined categories of income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","DEF","_Z",2019,"The CFC rules apply to resident companies and individuals, as well as any non-resident with a PE in Sweden, with an direct or indirect 25 % holding or control, by the taxpayer alone or together with associated persons, of capital or voting power in a foreign legal entity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","DEF","_Z",2024,"The CFC rules apply to resident companies and individuals, as well as any non-resident with a PE in Sweden, with an direct or indirect 25 % holding or control, by the taxpayer alone or together with associated persons, of capital or voting power in a foreign legal entity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GIB","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PHL","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TGO","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","YEAR","_Z",2019,"1999"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","YEAR","_Z",2024,"1999"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","SUB","_Z",2019,"There is no substantial activity carve out."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","SUB","_Z",2024,"The CFC rules do not apply if the CFC carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BHS","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BHS","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","SUB","_Z",2019,"CFC regime use a substance analysis only for certain categories of income if the CFC carries on an active business as described in question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","SUB","_Z",2024,"CFC rules do not apply if:     - the passive income is less than 10% of the total profits;     - the value of the assets of the CFC that may generate passive income do not exceed 20% of the total value of its assets; or     - the passive income of the CFC was subject to income tax at an effective rate of at least 30% in the CFC jurisdiction."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","EXE","_Z",2019,"For mixed income, the following rule is provided: Section 9 - Tax threshold for mixed income When applying section 7 (1), income with respect to which a foreign company is an intermediate company is not taken into account if the gross proceeds underlying it amounts to no more than 10 percent of the company's total gross proceeds, provided that the amounts not taken into account for a company or a taxpayer under this provision do not exceed a total of €80,000."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","EXE","_Z",2024,"Only passive income (e.g. interest) is subject to CFC taxation. Passive income means any income of the CFC which is not listed in Section 8 para. 1 AStG as active income. A typical example of passive (non-active) income is interest income. Active income (e.g. from a production activity) is excluded. In certain constellations, income that is subject to the Investment Tax Act (Investmentsteuergesetz) is also excluded. \n\nIncome from a relevant financial year is disregarded if the income does not exceed 10 percent of the total income of the foreign company, provided that the amounts to be disregarded for a taxpayer do not exceed a total of EUR 80,000.\n\nWith regard to the so-called motive test, see \"Substance requirements\""]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DJI","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DJI","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","EXE","_Z",2024,"CFCs which carry on a substantive economic activity supported by staff, equipment, assets and premises. For CFCs located in a non-EEA state, it is also required that Finland and the country in which the CFC is located have agreed on adequate exchange of information and that the CFC is engaged with production activity. The exclusion does not apply to CFCs located in a jurisdiction included in the EU list of non-cooperative jurisdictions for tax purposes."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","DEF","_Z",2019,"Applies a definition of CFC that also covers certain transparent entities and PEs.  A CFC is a foreign entity that is at least 50% owned by an Indonesian taxpayer or at least 50% collectively owned by Indonesian taxpayers.  The ownership threshold that is used to determine the CFC status is the ownership percentage at the end of the Indonesian taxpayer’s fiscal year, which is based on either the percentage of paid-up capital or the percentage of paid-up capital with voting rights.  CFC is a non-listed foreign entity"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","DEF","_Z",2024,"CFC rules apply to Indonesian taxpayers who control non-listed foreign entities (CFC).\nIndonesian taxpayers are deemed to get dividends from CFC.\nThe amount of deemed dividend is the percentage of ownership multiplied by the income of the CFC.\nThe income used to compute deemed dividends is derived from certain passive income (dividend, interest, royalty, capital gain, and rent from land and buildings).\nThe deemed dividend is due at the end of the fourth month after the tax returns reporting period ends."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IND","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IND","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","DEF","_Z",2019,"Greater than 50% of direct or indirect ownership in ordinary shares, voting rights or right to demand distributions. De facto control relationship."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","DEF","_Z",2024,"Greater than 50% of direct or indirect ownership in ordinary shares, voting rights or right to demand distributions. De facto control relationship."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","DEF","_Z",2019,"1) CFC rule from the EU Council Directive 2016/1164 (ATAD) applicable to companies; 2) CFC rule applicable to natural persons.The CFC rule in the CIT Law (Article 6) provides the definition of non-genuine arrangements, participation threshold, and limitation to apply CFC rule. The CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. CFC rule applies only in case of CFC&rsquo;s income arising from non-genuine arrangements that have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company&#39;s income. The CFC rule in the PIT Law (effective starting from 2013) is applicable to natural persons (article 17) of the law in Personal income Tax)  if at least 25% of a non-resident capital company (the stocks of which are not quoted in the regulated market of a European Union Member State or European Economic Area State), partnership or other legal person, a foreign foundation, trust or other legal entity set or established low tax or no tax countries and territories is owned or controlled, directly or indirectly, by resident taxpayers (individuals).  In this case profits of such company, partnership, person, foundation, trust or entity, whether distributed or not, are attributed proportionately to their resident shareholders and taxed accordingly (under individual income tax). The list of low tax or no tax countries and territories is established by the Cabinet of Ministers (Paragraph 1 of the Regulations of the Cabinet of Ministers dated of November 7, 2017 (No.655)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","DEF","_Z",2024,"  \t\t  As of January 1, 2019, there are two CFC rules in Latvia.     1) CFC rule from the EU Council Directive 2016/1164 (ATAD) applicable to companies;     2) CFC rule applicable to natural persons.         The CFC rule in the CIT Law (Article 6   1   ) provides the definition of non-genuine arrangements, participation threshold, and limitation to apply CFC rule. The CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. CFC rule applies only in case of CFC’s income arising from non-genuine arrangements that have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company's income.          The CFC rule in the PIT Law (effective starting from 2013) is applicable to natural persons (article 17   3    of the law in Personal income Tax)  if at least 25% of a non-resident capital company (the stocks of which are not quoted in the regulated market of a European Union Member State or European Economic Area State  )  , partnership or other legal person, a foreign foundation, trust or other legal entity set or established low tax or no tax countries and territories is owned or controlled, directly or indirectly, by resident taxpayers (individuals).  In this case profits of such company, partnership, person, foundation, trust or entity, whether distributed or not, are attributed proportionately to their resident shareholders and taxed accordingly (under individual income tax). The list of low tax or no tax countries and territories is governed by the Cabinet of Ministers (Regulations of the Cabinet of Ministers dated of June 27, 2023 (No.333).  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","YEAR","_Z",2019,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","YEAR","_Z",2024,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","YEAR","_Z",2019,"1988"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","YEAR","_Z",2024,"1988, with significant changes in 2012"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","SUB","_Z",2019,"The CFC rules do not have that kind of exemptions."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","SUB","_Z",2024,"The CFC rules do not have that kind of exemptions."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","SUB","_Z",2019,"Portuguese CFC rule is excluded if CFC undertakes substantial activities (agriculture or industry or, not predominantly in Portugal, commerce or services), being such activities the cause of at least 75% of his profits or incomes, and if in the CFC main activity are not included some well described operations, as credit, financial, insurance, holding and lease of goods ones with personnel, equipment, actives and installations."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","RUS","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","SUB","_Z",2019,"Exceptions are determined for CFC that carries on a substantive economic activity and in cases, where one third or less of the income accruing to the CFC falls within the determined categories of income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","URY","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","URY","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","EXE","_Z",2019,"The United States has two sets of CFC inclusion rules.  A U.S. shareholder must include in income their share of the subpart F income (generally, passive/mobile income) of a CFC.  The subpart F income rules include a </span><span class=csF52F8E4D>de minimis rule - income that would otherwise be subpart F income is not treated as subpart F income if it is less than the lesser of 5% of the CFC&rsquo;s gross income or USD $1,000,000.  However, all of a CFC&rsquo;s income will be treated as subpart F income if the CFC&rsquo;s subpart F income and insurance income exceeds 70% of the CFC&rsquo;s gross income.  The subpart F income rules also include a high tax exception &ndash; subpart F income that is subject to an effective rate of income tax imposed by a foreign country greater than 90% of the maximum rate of U.S. tax imposed on corporations (currently, greater than 18.9%).  The second set of rules (adopted in 2017) requires a U.S. shareholder to include in income their global intangible low-taxed income (GILTI).  The GILTI rules apply a formulaic approach which generally requires an income inclusion by the U.S. shareholder based on their share of the income of their CFCs after excluding a 10% return on tangible assets of the CFCs from the GILTI amount.  Such income also excludes income that is effectively connected to a trade or business in the United States (which is taxed separately), subpart F income, related-party dividends, foreign oil and gas extraction income, or income that would be subpart F but is excluded by the high-tax exception.  Proposed rules would expand, pursuant to an election, the GILTI regime&rsquo;s exclusion for high-taxed income to high taxed income that would not otherwise qualify as subpart F income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","EXE","_Z",2024,"  \t\t  The United States has two sets of CFC inclusion rules.  A U.S. shareholder must include in income their share of the subpart F income (generally, passive/mobile income) of a CFC.  The subpart F income rules include a   de minimis rule   - income that would otherwise be subpart F income is not treated as subpart F income if it is less than the lesser of 5% of the CFC’s gross income or USD $1,000,000.  However, all of a CFC’s income will be treated as subpart F income if the CFC’s subpart F income and insurance income exceeds 70% of the CFC’s gross income.  The subpart F income rules also include a high tax exception – subpart F income that is subject to an effective rate of income tax imposed by a foreign country greater than 90% of the maximum rate of U.S. tax imposed on corporations (currently, greater than 18.9%).  The second set of rules (adopted in 2017) requires a U.S. shareholder to include in income their global intangible low-taxed income (GILTI).  The GILTI rules apply a formulaic approach which generally requires an income inclusion by the U.S. shareholder based on their share of the income of their CFCs after excluding a 10% return on tangible assets of the CFCs from the GILTI amount.  Such income also excludes income that is effectively connected to a trade or business in the United States (which is taxed separately), subpart F income, related-party dividends, foreign oil and gas extraction income, or income that would be subpart F but is excluded by the high-tax exception.  In addition, the GILTI regime has an exclusion for high-taxed income, pursuant to an election, similar to the high tax exception for the Subpart F rules.  \n  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VCT","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VCT","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","SUB","_Z",2019,"Yes. There are provisions relating to foreign business establishments which result in net income being excluded for substantive businesses such as: a) a suitably equipped and staffed fixed base of business located outside South Africa solely or mainly for a purpose other than tax. b) a construction site lasting for at least 6 months. c) agricultural land used for bone fide farming activities. d) ships, vehicles, rolling stock and aircraft operated by the CFC or group company in a particular country."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","SUB","_Z",2024,"Foreign business establishment (FBE): \nthe net income of a CFC is deemed to be nil if all receipts and accruals are attributable to an FBE, defined as:    \n(a) a fixed place of business located in a country other than the Republic that is used or will continue to be used for the carrying on of the business of that CFC for a period of not less than one year, where—\n(i) that business is conducted through one or more offices, shops, factories, warehouses or other structures;\n(ii) that fixed place of business is suitably staffed with on­site managerial and operational employees of that controlled foreign company who conduct the primary operations of that business;\n(iii) that fixed place of business is suitably equipped for conducting the primary operations of that business;\n(iv) that fixed place of business has suitable facilities for conducting the primary operations of that business; and\n(v) that fixed place of business is located outside the Republic solely or mainly for a purpose other than the postponement or reduction of any tax imposed by any sphere of government in the Republic  \n(b) place where prospecting / exploring / producing natrual resources\n(c) a construction site lasting for at least 6 months   \n(d) agricultural land used for bone fide farming activities \n(e) ships, vehicles, rolling stock and aircraft operated by the CFC or group company in a particular country."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ALB","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HND","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ATG","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ATG","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","SUB","_Z",2024,"The CFC rules do not apply to entities or PEs which are engaged in significant economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","SUB","_Z",2019,"No."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","SUB","_Z",2024,"No."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","EXE","_Z",2019,"There are exemptions for passive income that would otherwise be included in CFC income, which, in general terms, apply where a CFC’s passive income is closely linked to an active business of another non-resident corporation in which the Canadian taxpayer has a significant interest. In order to qualify for one of these exemptions, the link between the passive income and the active business must be one of those described in the CFC legislation (and meet additional legislated conditions). Notably, these include passive income of the CFC that is directly related to active business activities of the other corporation, and passive income that derives from certain payments (e.g., interest) that are deductible in computing the active business income of the other corporation."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","EXE","_Z",2024,"There are no general exemptions based on whether the CFC is undertaking substantial activities. However, there are substance-based exceptions from certain specific rules in Canada's CFC regime that otherwise include a CFC's active business income in its CFC income. Very generally, if a CFC carries on an active business the principal purpose of which is to earn income that is of a type that is generally passive in nature (e.g., interest or royalty income), then the income is subject to the CFC rule, unless among other requirements the CFC carries on the business principally with arm's length persons and it employs more than five full-time employees in the active conduct of the business. There are also exceptions from the \"base erosion\" rules, which exceptions generally apply where more than 90 percent of the CFC's gross revenues from the specific activity to which a given base erosion rule applies (e.g., the lending of money to Canadian residents) derives from transactions with arm's length non-residents.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","EXE","_Z",2019,"CFC rules do not apply if:  - the passive income is less than 10% of the total profits;  - the value of the assets of the CFC that may generate passive income do not exceed 20% of the total value of its assets; or  - the passive income of the CFC was subject to income tax at an effective rate of at least 30% in the CFC jurisdiction."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","EXE","_Z",2024,"CFC regime use a substance analysis only for certain categories of    income if the CFC carries on an active business as described in question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CIV","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CIV","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COG","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COG","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COK","A","CFC","_Z",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COK","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","EXE","_Z",2024,"Yes, active income and dividends attributable to active income in the CFC are excluded from CFC taxes."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","SUB","_Z",2019,"The UK rules in relation to trading profits operate by reference to where the significant people functions (SPFs) that generate those profits are carried out, rather than by applying a generic test in relation to substantial activities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","SUB","_Z",2024,"The SPF approach in relation to trading profits and non-trade finance profits effectively applies a test of substance or relevant activity at an asset or risk level, which can be seen as a measure of relevant economic susbtance and activity. In addition, the rules apply a business premises condition in relation to trading profits and intra-group non-trading finance profits, which have to be occupied with a degree of permanence and from where the business of the CFC has to be carried on. For completeness, other exemptions include : Tax rate exemption - where the local tax paid is at least 75% of the tax that would have been paid in the UK.    De minimis threshold - less than £50k profits in a 12 month period, or less than £500k profits so long as passive interest income does not exceed £50k in that period.    Low profit margin exemption - where accounting profits are not more than 10% of relevant operating expenses.    Excluded countries list based on regimes with similar tax rules to UK, subject to an anti-avoidance test and limits on passive income.    Temporary exemption period for certain acquisitions, subject to anti-avoidance conditions.    Partial and full exemption for certain types of intra-group finance profits, subject to detailed anti-avoidance conditions.    Exemption for certain trading profits where a minority of significant people functions are carried out in the UK."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRL","A","EXE","_Z",2024,"If the local tax rate is lower than 3/4 of the Greenlandic tax rate, it is considered as a low taxed foreign jurisdiction. The Greenlandic CIT is 25 % for 2024."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","YEAR","_Z",2019,"2003"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","YEAR","_Z",2024,"2003"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","YEAR","_Z",2019,"2001"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","YEAR","_Z",2024,"2001"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","YEAR","_Z",2019,"1978"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","YEAR","_Z",2024,"1978"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LCA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LCA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MCO","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MCO","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","EXE","_Z",2019,"Malta has opted to implement the threshold exclusions set out in Sub-paragraph (4) of Article 7 of the EU Council Directive 2016/1164."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","EXE","_Z",2024,"Malta has opted for Sub-paragraph 2(b) of Article 7 of EU Council Directive 2016/1164. This targets any non-distributed income which arises from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","DEF","_Z",2019,"Control criteria: 1. There is deemed to be Norwegian control of a foreign company or undertaking if no less than one half of the ownership interests or capital of such company or undertaking are directly or indirectly owned or controlled by Norwegian taxpayers, at both the beginning and the end of the tax year. 2. There is also Norwegian control if the company or the undertaking were deemed to be Norwegian-controlled in the year before the tax year, unless less than one half of the ownership interests or capital are directly or indirectly controlled by Norwegian taxpayers, at both the beginning and the end of the tax year. 3. If Norwegian taxpayers own or control more than 60 percent of the ownership interests or capital as at the end of the tax year, there is Norwegian control irrespective of 1 and 2. Correspondingly, there is not Norwegian control if Norwegian taxpayers own or control less than 40 percent of the ownership interests or capital as at the end of the tax year.  Low-tax jurisdictions: Low-tax jurisdictions are jurisdictions in which the ordinary income tax on the overall profit of the company or undertaking is less than two thirds of the tax that would have been levied on such company or undertaking if it had been resident in Norway. The Norwegian tax rate in 2018 is 23 pct."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","DEF","_Z",2024,"Control criteria:    1. There is deemed to be Norwegian control of a foreign company or undertaking if no less than one half of the ownership interests or capital of such company or undertaking are directly or indirectly owned or controlled by Norwegian taxpayers, at both the beginning and the end of the tax year.    2. There is also Norwegian control if the company or the undertaking were deemed to be Norwegian-controlled in the year before the tax year, unless less than one half of the ownership interests or capital are directly or indirectly controlled by Norwegian taxpayers, at both the beginning and the end of the tax year.    3. If Norwegian taxpayers own or control more than 60 percent of the ownership interests or capital as at the end of the tax year, there is Norwegian control irrespective of 1 and 2. Correspondingly, there is not Norwegian control if Norwegian taxpayers own or control less than 40 percent of the ownership interests or capital as at the end of the tax year.        Low-tax jurisdictions: Low-tax jurisdictions are jurisdictions in which the ordinary income tax on the overall profit of the company or undertaking is less than two thirds of the tax that would have been levied on such company or undertaking if it had been resident in Norway. The Norwegian tax rate in 2018 is 23 pct."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","DEF","_Z",2019,"More than 50% owned by 5 or fewer residents,; or 40% or more owned by a single resident owner; or controlled by 5 or fewer residents. Usual aggregation and look through rules."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","DEF","_Z",2024,"\"Attributable CFC amount\" includes certain dividends, interest, royalties, rents, insurance income, income from supply of personal services, income from disposal of certain revenue account propery, income from services physically performed in NZ, and certain income related to telecommunications services. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","DEF","_Z",2019,"In the case of the Polish CFC rules, in principle, control is not defined directly, but an indication of its meaning can be gleaned from the first (of three) conditions for constituting a CFC. The CFC rules refer to the 50 per cent control threshold and say that a Polish taxpayer controls a foreign company if he owns continuously for at least 30 days, directly or indirectly, at least (i) 50 per cent of the company’s capital (legal control); (ii) 50 per cent of the voting rights in the controlling or administrative organs of the company (legal control); or (iii) 50 per cent of the shares related to the right to participate in the company’s profits (economic control). Moreover, a foreign company whose tax residence is in one of the 26 tax havens is considered a CFC regardless of the level of control over this company, level of taxation of its profits, or type of income received by it (CFC presumption). The Polish CFC rules apply also to the foreign permanent establishment of a Polish taxpayer."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","DEF","_Z",2024,"The CFC tax regime affects taxpayers that are shareholders of foreign entities located (i.e. seated or having a place of management or being registered or situated) in: \n(I) countries recognised as applying harmful tax competition i.e., in the so-called tax havens  \nor\n(II) countries with which Poland/EU have not ratified any treaty (e.g. DTTs) allowing for exchange of tax information \nNo other conditions have to be met in these cases for the foreign entity to be considered as a CFC.\nIn addition, a controlled foreign company (III) will be an entity that meets all of the following conditions:\nthe control level condition - Polish tax residents have directly/indirectly, solely or jointly with related entities or with non-related entities being Polish tax residents, over 50% participation in the foreign company’s income, voting rights, or capital or exercise actual control over the foreign entity.\nthe level of taxation condition - Income tax actually paid by the foreign entity (not subject to refund or credit in any form, including the refund or credit for the benefit of another entity) is lower by at least 25% than the income tax that would be paid by this foreign company in Poland at the application of the 19% tax rate (if it was a Polish tax resident)\nthe revenue structure condition – at least 33% of the revenue of this entity earned in the tax year comes from the indicated sources (so-called passive income)\nAs of 2022. there are also 2 more categories of CFC entities regarding so-called \"shell companies”\nThe first is entities (IV) that, in addition to meeting the level of control and the level of taxation conditions, have assets that generate passive income with a value equivalent to at least 50% of the value of the entity's total assets, and the passive income is less than 30% of the value of assets and receivables.\nThe last category of CFC (V) entities are those defined by reference to the rate of return on assets held. A foreign entity will be considered a CFC if, in addition to the level of control condition and the level of taxation condition, it earns income in excess of the income calculated according to the formula: (b + c + d) × 20%, in which the various letters stand for: b - the carrying value of the entity's assets, c - the entity's annual employment costs, d - the accumulated (summed) previous depreciation and amortization within the meaning of the accounting regulations, and less than 75% of the entity's income is derived from transactions with unrelated parties domiciled, established, managed, registered or located in the same country as the entity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TCA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TCA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","SUB","_Z",2019,"The United States CFC rules do not have a general substance requirement that would provide an exemption/exclusion to the CFC. But see response to question 7 for significant CFC exceptions/exclusions."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","SUB","_Z",2024,"The United States CFC rules do not have a general substance requirement that would provide an exemption/exclusion to the CFC."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ALB","A","EXE","_Z",2024,"Where the foreign controlled entity paid tax in its state of tax residence  on income included in the tax base of the physical person according to this Article, this tax may be credited against the overall tax liability."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AND","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AND","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","DEF","_Z",2024,"The CFC income is the entire income of the CFC regardless of its origin"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","DEF","_Z",2019,"Under the Danish CFC legislation, a Danish resident parent company is liable to taxation of the income of a non-resident subsidiary or a foreign permanent establishment to the extent of its participation if: the Danish parent company directly or indirectly controls more than 50% of its voting power; more than 50% of the subsidiary's taxable income derives from CFC-income; and at least 10% of the subsidiary's assets are CFC-assets."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","DEF","_Z",2024,"Under the Danish CFC legislation, a Danish resident parent company is liable to taxation of the income of a subsidiary to the extent of its participation if: the Danish parent company directly or indirectly owns more than 50% of its voting power/capital/profits; and more than 33% of the subsidiary's taxable income derives from CFC-income. The rules applies similarly to foreign permanent establishments."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EGY","A","DEF","_Z",2024,"N/A"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MAR","A","CFC","_Z",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MAR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","YEAR","_Z",2019,"1992"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","YEAR","_Z",2024,"1992"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRY","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRY","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","YEAR","_Z",2019,"1962, 2017"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","YEAR","_Z",2024,"1962, 2017"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","YEAR","_Z",2019,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","YEAR","_Z",2024,"2001"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AZE","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","WSM","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","DEF","_Z",2019,"CFC rules are applied to the following entities:  1) A trust located abroad as long as the Argentine resident manage its assets. As examples of the existence of this management can be mentioned:   a) When the trust is revocable trust.  b) When the trustor and the trust’s beneficiary are the same person.  c) When the Argentine resident has the right to directly invest or the assets of the trust.  2) An entity which is not considered taxpayer in the foreign country, that is to say, its profits are directly assigned to the Argentine resident.  3) An entity which is considered taxpayer in the foreign country, as long as some requirements take place concurrently. These requirements are:  a) The Argentine resident control, directly or directly, the entity located in the other country. b) The non resident entity does not have the material and human resources to perform its activity or its passive and portfolio income are equal or greater than 50% of the entity profits, or its profits result on deductible expenses for related parties in Argentina. c) The income or profits mentioned in b) are taxed at a rate below than 75% of the rate at which those income or profits would have been taxed in Argentina, or the entity in question is located in a non-cooperative or low or no tax jurisdiction or country.  In order to determiner the condition mentioned in a), i.e. if the Argentine resident controls the entity located in other country, one of these cases has to take place:  a) The Argentine resident, directly or indirectly, owns 50% or more of the foreign entity net worth or profits. b) The Argentine resident, directly or indirectly, has 50% or more of the votes for taking decisions in the foreign entity. c) The Argentine resident, directly or indirectly, has the right to manage and sell the entity goods and properties. d) The Argentine resident, direct or indirectly, has the votes to appoint the board of directors of the entity. e) The Argentine resident takes part in the board of directors and has in it the votes to impose decisions. f) The Argentine resident, directly or indirectly, has the votes to dismiss the CEO or managers of the entity. g) The Argentine resident has any right on the entity profits. h) At least 30% of the value of the entity assets arises from financial investments that generate passive income from Argentine source. i) Passive and portfolio income obtained by the entity is taxed at a rate below than 75% of the rate at which those income would have been taxed in Argentina.  As regards indirect control, it takes place when the Argentine resident controls the foreign entity (i.e. one of the facts listened above takes place) through one of these means:  a) An entity which is controlled by the Argentine resident. b) Argentine resident’s relative (e.g.: spouse). c) The person who cohabits with the Argentine resident.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","DEF","_Z",2024,"CFC rules are applied to the following entities:        1) A trust located abroad as long as the Argentine resident manage its assets. As examples of the existence of this management can be mentioned:         a) When the trust is revocable trust.     b) When the trustor and the trust’s beneficiary are the same person.     c) When the Argentine resident has the right to directly invest or the assets of the trust.        2) An entity which is not considered taxpayer in the foreign country, that is to say, its profits are directly assigned to the Argentine resident.        3) An entity which is considered taxpayer in the foreign country, as long as some requirements take place concurrently. These requirements are:        a) The Argentine resident control, directly or directly, the entity located in the other country.    b) The non resident entity does not have the material and human resources to perform its activity or its passive and portfolio income are equal or greater than 50% of the entity profits, or its profits result on deductible expenses for related parties in Argentina.    c) The income or profits mentioned in b) are taxed at a rate below than 75% of the rate at which those income or profits would have been taxed in Argentina, or the entity in question is located in a non-cooperative or low or no tax jurisdiction or country.        In order to determiner the condition mentioned in a), i.e. if the Argentine resident controls the entity located in other country, one of these cases has to take place:        a) The Argentine resident, directly or indirectly, owns 50% or more of the foreign entity net worth or profits.    b) The Argentine resident, directly or indirectly, has 50% or more of the votes for taking decisions in the foreign entity.    c) The Argentine resident, directly or indirectly, has the right to manage and sell the entity goods and properties.    d) The Argentine resident, direct or indirectly, has the votes to appoint the board of directors of the entity.    e) The Argentine resident takes part in the board of directors and has in it the votes to impose decisions.    f) The Argentine resident, directly or indirectly, has the votes to dismiss the CEO or managers of the entity.    g) The Argentine resident has any right on the entity profits.    h) At least 30% of the value of the entity assets arises from financial investments that generate passive income from Argentine source.    i) Passive and portfolio income obtained by the entity is taxed at a rate below than 75% of the rate at which those income would have been taxed in Argentina.        As regards indirect control, it takes place when the Argentine resident controls the foreign entity (i.e. one of the facts listened above takes place) through one of these means:        a) An entity which is controlled by the Argentine resident.    b) Argentine resident’s relative (e.g.: spouse).    c) The person who cohabits with the Argentine resident.        "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","DEF","_Z",2019,"There are three types of CFC: branch, controlled and affiliated. - In the controlled type, the controller has the right to make corporate decisions and to choose the majority of the management team.  - In the affiliated type, the controller has a significant influence in such decisions. Significant influence means the right to take part in the decisions concerning financial or operational policies. A controller that holds 20% or more of the voting capital of a company is deemed to have significant influence on this company."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","DEF","_Z",2024,"Profits, income and capital gains earned abroad shall be computed in determining the actual profit of legal entities corresponding to the balance sheet drawn up on December 31st of each year. Accordingly, any investment in a controlled foreign entity must be adjusted yearly to reflect the change in the investment value corresponding to the profits or losses of the directly and/or indirectly controlled entity. The change in investment must be recognised in proportion to the Brazilian parent’s participation in its equity, and any positive adjustment relating to profits earned, calculated under the local accounting standards of the jurisdiction of the controlled entity, must be subject to IRPJ and CSLL annually."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","SUB","_Z",2019,"The Danish rules are not subject to any substance test."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","SUB","_Z",2024,"The Danish rules do not include a general substance test. There is a partial substance test that is applicable for companies with embedded royalty income.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EGY","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EGY","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","EXE","_Z",2019,"Tax rate exemption - where the local tax paid is at least 75% of the tax that would have been paid in the UK. De minimis threshold - less than £50k profits in a 12 month period, or less than £500k profits so long as passive interest income does not exceed £50k in that period. Low profit margin exemption - where accounting profits are not more than 10% of relevant operating expenses. Excluded countries list based on regimes with similar tax rules to UK, subject to an anti-avoidance test and limits on passive income. Temporary exemption period for certain acquisitions, subject to anti-avoidance conditions. Partial and full exemption for certain types of intra-group finance profits, subject to detailed anti-avoidance conditions. Exemption for certain trading profits where a minority of significant people functions are carried out in the UK."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","EXE","_Z",2024,"The UK rules in relation to trading profits operate by reference to where the significant people functions (SPFs) that generate those profits are carried out, rather than by applying a generic test in relation to substantial activities. Broadly speaking, a CFC charge arises  in respect on any trading profits where the majority of the SPFs which generate those profits are carried out in the UK. For trading finance profits (banking and insurance) a charge will arise where the CFC is overcapitalised with funds received from UK connected persons (UK group companies). For non-trade finance profits, a charge will arise in relation to funds generated by UK SPFs, funds generated by UK connected capital (from UK group companies), arrangements in lieu of dividends to the UK and certain leasing arrangements. For certain intra-group financing arrangements, a partial (75%) exemption can be applied and, in limited circumstances, a full (100%) exemption can apply. Other entity level exemptions can apply in relatio to low profits, low profit margins, high effective tax rates (at least 75% of UK corporation ETR) and excluded countries with similar tax base/rate to UK."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GEO","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GEO","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","EXE","_Z",2019,"The CFC rules will not apply where the arrangements under which SPFs are performed have been entered into on an arm's length basis or are subject to Ireland's Transfer Pricing regime. There are exemptions for CFCs with low accounting profits or a low profit margin. An 'effective tax rate' exemption can apply where the tax paid by the CFC in its jurisdiction is greater than the difference between the tax it pays in its territory and the tax it would have paid in the State. A one-year grace period is also allowed in respect of newly-acquired CFCs where certain conditions apply. Relief is also available on certain distributions and on certain disposals of shares or securities in a CFC. In order to prevent double taxation, a credit will be available for any tax paid by the CFC arising in its jurisdiction or any other jurisdiction (including Ireland) on the chargeable income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","EXE","_Z",2024,"The exemptions that apply include scenarios where the CFC pays a comparatively higher amount of tax in its territory than it would have paid in the State (section 835T Effective tax rate exemption), the low profit margin exemption (section 835U), the low accounting profit exemption (section 835V) and the exempt period exemption (section 835W).  The CFC rules will not apply where the arrangements, under which SPFs are performed, have been entered into on an arm’s length basis or are subject to the Transfer Pricing regime under Part 35A, TCA (section 835R). "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","DEF","_Z",2019,"If a person resident in Italy (a legal entity, partnership, individual) holds, directly or indirectly, also through trust companies, the control of an enterprise, company or other entity, resident or located in States or Territories permitting privileged tax regimes, the income earned by the controlled foreign entity is imputed to the resident entity or person, as of the end of the fiscal year of the controlled foreign entity. The relevant control is based on the civil law, which is described in article 2359 Civil Code. Subsidiaries enterprises are: 1) companies in which another company has the majority of the votes that can be exercised in the general shareholders' meeting; 2) companies in which another company has sufficient votes to exercise a significant influence in the general shareholders' meeting; 3) companies that are under the significant influence of another company by virtue of particular contractual obligations with it 4). A tax regime is privileged where the nominal level of taxation is less than 50 percent of that applicable in Italy."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","DEF","_Z",2024,"If a person resident in Italy (a legal entity, partnership, individual) holds, directly or indirectly, also through trust companies, the control of an enterprise, company or other entity, resident or located in States or Territories permitting privileged tax regimes, the income earned by the controlled foreign entity is imputed to the resident entity or person, as of the end of the fiscal year of the controlled foreign entity. The relevant control is based on the civil law, which is described in article 2359 Civil Code. Subsidiaries enterprises are:    1) companies in which another company has the majority of the votes that can be exercised in the general shareholders' meeting;    2) companies in which another company has sufficient votes to exercise a significant influence in the general shareholders' meeting;    3) companies that are under the significant influence of another company by virtue of particular contractual obligations with it .   4). A tax regime is \"privileged\" where the effective level of taxation is less than 15%. The effective level of taxation is computed based on total taxes and profit(loss) before taxes as from financial accounts. Financial accounts must be subject to accounting revision.  If either the financial accounts are not revised or the effective taxation is below 15%, the controlling entity must verify that the controlled company is not subject to an effective taxation less than 50 percent of that applicable in Italy. A  subsidiary is deemed CFC if more than 1/3 of its proceeds consists of passive income (interests, royalties, dividends and other types of financial income). The relevant legislation is avaialble in art.167 of the Direct Taxes Code (Law n. 917 of 22/12/1996) as modified by the legislative decree n. 209 of 27/12/2023."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","SUB","_Z",2019,"The Polish CFC rules do not apply to a non-resident company if the non-resident company is established and subject to tax on the worldwide income in a EU/EEA country, provided it meets the substantial genuine business activity test. When assessing whether a CFC carries out a genuine economic activity, the Polish CFC rules recommend paying particular notice to whether: (i) the registration of a CFC matches an actual establishment intended to carry on genuine economic activities, i.e. the company has local, qualified personnel and the requisite equipment; (ii) a CFC has been created as a structure functioning in isolation for economic reasons; (iii) the premises, personnel or equipment of a CFC are commensurate with the scope of its activities; (iv) arrangements concluded by the CFC are consistent with economic reality, have an economic justification, and are not manifestly contrary to the general economic interests of the company; and (v) a CFC independently performs its basic economic functions with the use of its own resources, including managers at the company’s location."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","SUB","_Z",2024,"When assessing whether a CFC carries out real economic activity, the Polish CFC rules recommend paying particular notice to whether: \n(i) the registration of a CFC matches an actual establishment intended to carry on real economic activities, i.e. the company has local, qualified personnel and the requisite equipment; \n(ii) a CFC has not been created as a structure functioning in isolation from economic reasons; \n(iii) the premises, personnel or equipment of a CFC are commensurate with the scope of its activities; \n(iv) arrangements concluded by a CFC are consistent with economic reality, have an economic justification, and are not manifestly contrary to the general economic interests of the company; and \n(v) a CFC independently performs its basic economic functions with the use of its own resources, including managers at the company’s location."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","RUS","A","YEAR","_Z",2019,"2015"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SEN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SEN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","EXE","_Z",2019,"N/A"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","EXE","_Z",2024,"No, see answer in question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","YEAR","_Z",2019,"1989"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","YEAR","_Z",2024,"1989"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","DEF","_Z",2024,"Corporate income of foreign subsidiaries controlled by full fledged taxpayer real persons and institutions by holding at least 50% of their capital, dividend or voting right directly or indirectly, seperately or together, is subject to Corporate Income Tax in Türkiye whether distributed or not, if the conditions specified in Article 7 of Law No. 5520 (Corporate Income Tax) are met together."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ALB","A","SUB","_Z",2024,"If the \"passive income\" does not exceed 30 percent of the total profit of the foreign controlled entity, the CFC provisions do not apply."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JOR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","EXE","_Z",2019,"CFC law standards are not applied:  A) When the entity resident in the other country is, according to Argentine rules, a permanent establishment (PE) in that other country. In that case the specific Argentine rules for PE located outside Argentina shall be applied.  B) When the Argentine entity is a financial entity according to the Argentine Law of Financial Entities (Law 21526).  C) When the Argentine entity is an insurance company according to the Argentine Law of Insurance Companies and Insurance Company’s Control (Law 20091).  D) When the Argentine entity is a trust/common fund and investment company according to the Argentine Law of Trust/Common Fund and Investment Company (Law 24083).  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","EXE","_Z",2024,"One of the situations that, concurrently with others (see question 4), shall take place in order to apply CFC rules is that the non resident entity does not have the material and human resources to perform its activity or its passive income are at less 50% of the entity profits, or its profits result on deductible expenses for related parties in Argentina. Therefore, if this conditions are not meet the CFC rules are not applied."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","SUB","_Z",2019,"One of the situations that, concurrently with others (see question 4), shall take place in order to apply CFC rules is that the non resident entity does not have the material and human resources to perform its activity or its passive income are at less 50% of the entity profits, or its profits result on deductible expenses for related parties in Argentina. Therefore, if this conditions are not meet the CFC rules are not applied."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","DEF","_Z",2019,"A foreign company will be considered as a CFC if the following two conditions are simultaneously satisfied:  - The control test: the Belgian taxpayer owns (directly or indirectly) the majority of voting rights of the foreign company, or has (directly or indirectly) a stake of at least 50% in the capital of this company, or is entitled to at least 50% of the profits of this company; and  - The taxation test: in the country or jurisdiction where it is situated, the foreign company/PE is either not subject to income tax or subject to income tax less than half of the income tax if the company would have been located in Belgium."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","DEF","_Z",2024,"A foreign company will be considered as a CFC if the following two conditions are simultaneously satisfied:     - The control test: the Belgian taxpayer owns with or without its associated entities the majority of the voting rights attached to the total of the shares of the foreign company, or holds together with its associated entities a stake of at least 50% in the capital of this company, or is together with its associated entities entitled to at least 50% of the profits of this company; and     - The taxation test: in the country or jurisdiction where it is situated, the foreign company/PE is either not subject to income tax or subject to income tax less than half of the income tax if the company/PE would have been located in Belgium."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","DEF","_Z",2019,"Control test criteria consider a foreign entity to be controlled if residents of Chile have:  - 50% or more of the foreign entity's capital, profits or voting power;  - the power to elect the majority of directors or administrators of the foreign entity; or  - the power to unilaterally amend the foreign entity's by laws, or to change the majority of its directors or administrators.  A foreign entity is deemed to be a CFC if:  - it is resident in a low-tax jurisdiction as defined in article 41H of the Income Tax Law; or  - a person resident of Chile has directly or indirectly a purchase option with respect to the foreign entity for 50% or more of its capital, profits or voting power."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","DEF","_Z",2024,"Control test criteria consider a foreign entity to be controlled if residents of Chile have:     - 50% or more of the foreign entity's capital, profits or voting power;     - the power to elect the majority of directors or administrators of the foreign entity; or     - the power to unilaterally amend the foreign entity's by laws, or to change the majority of its directors or administrators.        A foreign entity is deemed to be a CFC if:     - it is resident in a low-tax jurisdiction as defined in article 41H of the Income Tax Law; or     - a person resident of Chile has directly or indirectly a purchase option with respect to the foreign entity for 50% or more of its capital, profits or voting power."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","YEAR","_Z",2019,"2014"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHL","A","YEAR","_Z",2024,"2016"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","DEF","_Z",2019,"German taxpayers have to hold more than 50 percent of the foreign companies shares. Thereby the size of the participation of each single shareholder is irrelevant."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","DEF","_Z",2024,"Passive income of a controlled foreign company (so-called intermediate company) is generally subject to CFC-taxation in accordance with Sections 7 et seq. AStG if the income is subject to low taxation abroad. This is the case if the income tax burden abroad is less than 15% (so-called low tax threshold, Section 8 para. 5 AStG).\n\nControl exists if more than 50% of the shares or voting rights in the nominal capital are directly or indirectly attributable to the German Shareholder alone or jointly with related parties, or if the German Shareholder is directly or indirectly entitled to more than half of the profits or liquidation proceeds of that company at the end of the fiscal year.\n"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","SUB","_Z",2019,"Section 8 paragraph 2 provides a so called motive test which allows the tax payer to prove that the company pursues an actual economic activity as far as the companies registered office is located in an EU-member State."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","SUB","_Z",2024,"The so-called motive test in section 8 para. 2 and 3 AStG - also known as the substance test or escape clause - gives the shareholders of EU/EEA intermediate companies the opportunity to prove sufficient substance, i.e. a genuine economic activity of the company, and thus avoid CFC taxation. The taxpayers involved in the intermediate company can prove that the company pursues an actual economic activity in the country in which it is domiciled or has its management.  \n\nIf the proof is successful, the CFC taxation does not apply. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","DEF","_Z",2019,"Applies a definition of CFC that also covers certain transparent entities and Pes.  Applies a legal and economic control test for defining a CFC : controls more than half of its voting rights or its subscribed capital, directly or indirectly, or is entitled to more than half of its after-tax profit"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","DEF","_Z",2024,"Applies a definition of CFC that also covers certain transparent entities and Pes.        Applies a legal and economic control test for defining a CFC : controls more than half of its voting rights or its subscribed capital, directly or indirectly, or is entitled to more than half of its after-tax profit"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","SUB","_Z",2019,"A foreign person is not deemed a CFC if there is real economic substance (i.e. adequate personnel, equipment, assets, and location to effectively carry out business activities) attributable to that person.  This condition is deemed to be fulfilled where the income from specified activities pursued with the entity’s/PE’s own assets and employees amount to at least 50% of its total income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JAM","A","CFC","_Z",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JAM","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LBR","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LBR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","SUB","_Z",2019,"CFC rules are not applied in cases when CFC (except for the CFC, registered or otherwise organised in the target territory (blacklisted jurisdictions)) has staff members and uses assets to ensure actual economic activities in the jurisdiction where this CFC is registered or otherwise organised."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","SUB","_Z",2024,"CFC rules are not applied if (except for the CFC, registered or otherwise organised in the target territory (blacklisted jurisdictions)):- passive income of the CFC does not exceed 1/3 of total income of this CFC during the tax period; or- actual corporate income tax paid on income of the CFC following the rules on corporate income tax or equivalent tax applied in this foreign state is not lower than 50 % of actual corporate income tax on income of CFC which would have been computed following the Lithuanian CFC rules."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","SUB","_Z",2019,"The regime is not applicable if the foreign entity carries out active business activities, unless their passive income is greater than 20% of their total income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SGP","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SGP","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SYC","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SYC","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ALB","A","YEAR","_Z",2024,"2024"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","YEAR","_Z",2019,"1990"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","YEAR","_Z",2024,"1990"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","YEAR","_Z",2019,"2017"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","YEAR","_Z",2024,"2024"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRA","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BWA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BWA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","SUB","_Z",2019,"Ireland selected Option B in accordance with Article 7(2)(b), ATAD. The rules operate by attributing undistributed income of the CFCs, arising from non-genuine arrangements put in place for the essential purpose of avoiding tax, to the controlling company, or a connected company in Ireland, for taxation, where the controlling company or the connected company have been carrying out &tilde;significant people functions&quot;(SPFs) in Ireland"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","SUB","_Z",2024,"The CFC rules are an anti-abuse measure, designed to prevent the artificial diversion of profits from controlling companies to offshore entities in low or no-tax jurisdictions (the CFCs). The rules operate by attributing undistributed income of the CFCs, arising from non-genuine arrangements put in place for the essential purpose of avoiding tax, to the controlling company, or a connected company in the State for taxation, where the controlling company, or a connected company, carry out relevant Irish activities (i.e. significant people functions (SPFs) or key entrepreneurial risk-taking functions (KERTs) in the State). In that regard, the CFC rules focus less on substance in the CFC and focus more on what activity is being carried out on its behalf in the controlling company.  The rules require an analysis as to the extent to which the CFC would hold assets or bear risks were it not for the controlling company, or a connected company, undertaking the SPFs or KERTs in relation to those assets and risks."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ITA","A","SUB","_Z",2019,"The Italian-resident taxpayer which controls the CFC could apply for a tax ruling claiming the non-application of the CFC rules. In case of non-UE resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that: - the CFC predominantly carries out, as its main business purpose, an industrial activity within the local market, i.e. within the market of the country where the company is located. The non-resident company must be economically and socially integrated in this market, and the presence of a real business organisation in such market is not enough (c. 51/E/2010). For banks, financial institutions and insurance companies, this evidence is deemed to be given if most of the funds, investments, and proceeds arise from the jurisdiction where these entities are located; or - alternatively, the participation in the CFC does not achieve the result of shifting income to low-tax jurisdictions. In case of EU resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that: - the CFC does not represent a wholly artificial arrangement aimed at obtaining an undue tax advantage (see at Cadbury-Schweppes decision by EUCJ)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","EXE","_Z",2019,"CFC rules do not apply in the case of a company whose actually accrued annual income is 200 million won or less."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","EXE","_Z",2024,"Yes, if the CFC actively engages in business operations through an office, a shop, or a factory, in the foreign jurisdiction then the CFC rules will not apply. This exemption, however, does not apply to a CFC:    (i) which is engaged in certain businesses such as wholesale trade, financial and insurance business, real estate, lease business, etc. or    (ii) which derives passive incomes from holding stocks or bonds, provision of intellectual property rights, leasing of vessels, aircraft, and heavy equipment, etc."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","SUB","_Z",2019,"Yes, if the CFC actively engages in business operations through an office, a shop, or a factory, in the foreign jurisdiction then the CFC rules will not apply. This exemption, however, does not apply to a CFC: (i) which is engaged in certain businesses such as wholesale trade, financial and insurance business, real estate, lease business, etc. or (ii) which derives passive incomes from holding stocks or bonds, provision of intellectual property rights, leasing of vessels, aircraft, and heavy equipment, etc."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","YEAR","_Z",2019,"Entry into force on 13. July 2018 and applicable for taxable periods starting 1. January 2019."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","EXE","_Z",2019,"CFC rules are not applied if (except for the CFC, registered or otherwise organised in the target territory (blacklisted jurisdictions)):- passive income of the CFC does not exceed 1/3 of total income of this CFC during the tax period; or- actual corporate income tax paid on income of the CFC following the rules on corporate income tax or equivalent tax applied in this foreign state is not lower than 50 % of actual corporate income tax on income of CFC which would have been computed following the Lithuanian CFC rules."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","EXE","_Z",2024,"CFC rules are not applied in cases when CFC (except for the CFC, registered or otherwise organised in the target territory (blacklisted jurisdictions)) has staff members and uses assets to ensure actual economic activities in the jurisdiction where this CFC is registered or otherwise organised."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","EXE","_Z",2019,"As the main rule of the Mexican CFC legislation, the CFC's income needs to be subject to an income tax that is equivalent to at least 75% of the income tax that would have been paid in Mexico. Income taxed at a statutory rate of at least 22.5%, provided that all income is taxable, except dividends paid between entities that are residents of the same jurisdiction and that their deductions have been actually incurred. Royalties received by foreign entities for the use or concession of use of a patent or industrial secrets, provided that some conditions are met. Our control test is set as an exclusion (see question 4). Income derived from restructuring operations, under certain conditions. Mexican authorities can authorize Mexican residents not to apply CFC legislation if the controlled entity has authorization to act as a financial institution in the country it resides."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","EXE","_Z",2024,"The regime is not applicable if the foreign entity carries out active business activities, unless their passive income is greater than 20% of their total income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MKD","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MKD","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","EXE","_Z",2019,"Australian companies not subject to the CFC regime."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","EXE","_Z",2024,"Active income\nAustralian resident companies"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","OMN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","OMN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VGB","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VGB","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ALB","A","DEF","_Z",2024,"When a physical personal has an interest in a foreign controlled entity, the profits of which are not taxable or exempt from tax in  the Republic of Albania, any retained earnings arising from 'passive income', shall be included in physical person’s taxable investment income.                                                                     Any foreign entity is considered a controlled foreign entity when the following conditions are met:\na) the physical person, or together with related persons, has a direct or indirect participation of more than 50 percent of the voting rights, or directly or indirectly owns more than 50 percent of the capital, or have the right to receive more than 50 percent of the profit of that entity; and\nb) the current tax paid on its profit by the entity is less than 50 percent of the tax that would have been charged to the entity if it had been a resident entity in  the Republic of Albania."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWZ","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","EXE","_Z",2019,"Austria opted to implement the two exemptions stipulated in Article 7 paragraph 3 ATAD 1."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","EXE","_Z",2024,"The CFC rules do not apply where the CFC carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances (Article 7 paragraph 2 point a ATAD). The exemption is applicable to CFC located in an EU-Member State as well as for CFC located in a third country that is not party to the EEA Agreement."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BGR","A","EXE","_Z",2024,"The CFC rules do not apply to entities or PEs which are not subject to corporate tax in the jurisdiction of establishment"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRB","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRB","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","DEF","_Z",2019,"Generally, a CFC is a foreign affiliate that is legally controlled by the Canadian shareholder, or that would be controlled by the shareholder if the shareholder owned all of the shares of the foreign corporation that are owned by the taxpayer, persons that do not deal at arm's length with the taxpayer, and any other four Canadian residents. A foreign affiliate of a Canadian taxpayer is a non-resident corporation, where at least 1 percent of the shares of any class are owned, directly or indirectly, by the Canadian shareholder and at least 10 percent of the shares of any class are owned, directly or indirectly, by the Canadian shareholder together with related persons."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","DEF","_Z",2024,"Generally, a CFC is a \"foreign affiliate\" that is legally controlled by the Canadian shareholder, or that would be controlled by the shareholder if the shareholder owned all of the shares of the foreign corporation that are owned by the taxpayer, persons that do not deal at arm's length with the taxpayer, and any other four Canadian residents. A \"foreign affiliate\" of a Canadian taxpayer is a non-resident corporation, where at least 1 percent of the shares of any class are owned, directly or indirectly, by the Canadian shareholder and at least 10 percent of the shares of any class are owned, directly or indirectly, by the Canadian shareholder together with related persons."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CUW","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CUW","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","EXE","_Z",2019,"An exemption from CFC taxation exists for intermediate local holding companies. In principle, transactions between a subsidiary resident in the same country and the intermediate holding company are disregarded."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","EXE","_Z",2024,"An exemption from CFC taxation exists for intermediate local holding companies. Such local holding companies are instead consolidated with their subsidiaries in the same country when testing whether the requirements for CFC taxation is fullfilled. Transactions between a subsidiary resident in the same country and the intermediate holding company are disregarded in this consolidation."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DNK","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EGY","A","EXE","_Z",2024,"* IF the ownership in the non resident company is less than 10%, then it is excluded.\n* If the revenues of the non resident company resulted from dividends, interest, royalties, management fees, or rents is less than 70%, then it is excluded.\n* application is limited to resident entities.\n*Revenues of the non resident entities are subject to tax or taxable at a rate exceeds 75% of Egypt's corporate tax rate (22.5%)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EGY","A","YEAR","_Z",2024,"2015"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","DEF","_Z",2019,"A foreign entity, provided that the requirements for ownership (at least 25 % by the taxpayer itself or together with associated enterprises) and low tax rate (the actual corporate tax paid by the foreign entity on its profits is lower than three fifth's of the tax that would've been payable on the same income according to Finnish corporate income tax rules) are fulfilled."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FIN","A","DEF","_Z",2024,"A foreign entity, provided that the requirements for ownership (at least 25 % by the taxpayer itself or together with associated enterprises) and low tax rate (the actual corporate tax paid by the foreign entity on its profits is lower than three fifth's of the tax that would've been payable on the same income according to Finnish corporate income tax rules) are fulfilled."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GAB","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GAB","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","SUB","_Z",2019,"CFC rules do not apply in cases where the legal person or entity is resident for tax purposes in an EU member state, unless the establishment or financial activity of the legal person or entity constitutes a fictitious arrangement made essentially with the intention to avoid the applicable tax. In case the legal person or entity is resident for tax purposes in a country which is a party to the EEA agreement and an information exchange agreement is in force and implemented commensurate with the exchange of information upon request provided in Directive 2011/16/EU, CFC rules do not apply, unless the establishment or financial activity of the legal person or entity constitutes a fictitious arrangement made essentially with the intention to avoid the applicable tax."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","SUB","_Z",2024,"It is pointed out that the Tax Authority bears the burden of proof that the CFC established in an EU/EEA member country does not carry out a substantial economic activity, which is supported by staff, equipment, assets and premises.\nOn the contrary, the tax authority does not have this burden if the CFC, as defined, is a resident a of a third country or, in case that the CFC has a permanent establishment is established in a third country, which is not a contracting party part of the EEA Agreement. In this case, the provisions of the CFC apply even if the CFC carries out a substantial economic activity.\nThe relevant provisions do not include a substantial economic activity test other than mentioned above.\n\nAs mentioned above (question 4) companies of which the main class of shares of which are traded on a regulated market are excluded (i.e. listed companies are excluded)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","DEF","_Z",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","YEAR","_Z",2019,"2010"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","YEAR","_Z",2024,"2010"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KEN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KEN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KNA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KNA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KOR","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","DEF","_Z",2019,"Implementation of switch over provisions for dividends (see Art. 48 para. 3 letter b of the Tax Act)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MDV","A","EXE","_Z",2024,"CFCs are allowed tax credit under Section 72 of the Income Tax Act of Maldives. \nWhere any person resident in the Maldives has paid tax in a foreign country or territory on any part of the person’s income which arises from a source outside Maldives and which is also chargeable to tax under this Act in any accounting period, that person shall be\nentitled to deduct from the amount of tax imposed under this Act an amount equal to the lesser of:\n(1) the amount of foreign tax paid;\n(2) tax payable in the Maldives from the net amount of foreign sourced income"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MDV","A","YEAR","_Z",2024,"2021"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","DEF","_Z",2019,"Malta has implemented the EU Council Directive 2016/1164. The constituent elements of a CFC is determined on the level of a control maintained by the controlling entity and the level of the effective taxation levied in the jurisdiction of the CFC."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","DEF","_Z",2024,"Malta has implemented the EU Council Directive 2016/1164. The constituent elements of a CFC is determined on the level of a control maintained by the controlling entity and the level of the effective taxation levied in the jurisdiction of the CFC."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","EXE","_Z",2019,"Beyond the above described exemption, there is no exemption or exclusion from the Polish CFC rules. However, low actual tax paid by a CFC may be considered as a kind of exclusion from the Polish CFC rules - the tax actually paid by the CFC is lower than the difference between the corporate income tax that would have been charged on the CFC under the Polish tax system and the actual corporate income tax paid by the CFC. For example, if the CFC actually paid more than 9,5 per cent of tax (50% of the Polish 19% ordinary tax rate for corporate taxpayers), while the corresponding Polish company would have been paid 19%, then the CFC's is excluded from the taxation under the Polish CFC rules (in fact such company would not be considered as a CFC because it will not meet on of the three conditions to become a CFC, i.e. low level of actual taxation)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","EXE","_Z",2024,"(I) The Polish CFC rules do not apply to a non-resident company if the non-resident company is established and subject to tax on the worldwide income in a EU/EEA country, provided it meets the substantial real economic activity test. \n(II) In order to avoid double taxation (in the economic sense), a tax deduction has been introduced for the amount of income tax paid by a foreign controlled company in its country of residence. This deduction is made in the proportion in which the income of this company determined for the purposes of the CFC regulations (i.e., the income included in the tax base, after deducting the amounts of dividends received by the taxpayer from the foreign controlled entity and the amounts obtained from the taxpayer's disposal of its interest in the foreign controlled company for consideration) remains to the total income of this company. \n(III) Elimination of double or multiple income taxation on CFC income in cases of cascading dividends in holding structures"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","DEF","_Z",2019,"The control test is in line with the Article 7(1) of the EU Anti-Tax Avoidance Directive 2016/1164 (ATAD). The control test for a control foreign company is as follows [ITA Sec. 17h para 1 letter a)]: a corporate taxpayer (tax resident of the Slovak Republic) by itself, or together with its associated enterprises owns directly or indirectly more than 50% of the capital or holds a direct or indirect participation of more than 50% of the voting rights or is entitled to receive more than 50% of the profits of the foreign entity. Other condition, which has to be fulfilled is a tax rate test, i.e. the corporate tax paid by the controlled foreign company abroad is lower than the difference between the corporate tax of the controlled foreign company calculated under the Slovak Income Tax Act and the corporate tax paid by the controlled foreign company abroad [ITA Sec. 17h para 1 letter b)]. As the controlled foreign company is considered also the permanent establishment [ITA Sec. 17h para 3]. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","DEF","_Z",2024,"The control test is in line with the Article 7(1) of the EU Anti-Tax Avoidance Directive 2016/1164 (ATAD). The control test for a control foreign company is as follows [ITA Sec. 17h para 1 letter a)]: a corporate taxpayer (tax resident of the Slovak Republic) by itself, or together with its associated enterprises owns directly or indirectly more than 50% of the capital or holds a direct or indirect participation of more than 50% of the voting rights or is entitled to receive more than 50% of the profits of the foreign entity.    Other condition, which has to be fulfilled is a tax rate test, i.e. the corporate tax paid by the controlled foreign company abroad is lower than the difference between the corporate tax of the controlled foreign company calculated under the Slovak Income Tax Act and the corporate tax paid by the controlled foreign company abroad [ITA Sec. 17h para 1 letter b)].    As the controlled foreign company is considered also the permanent establishment [ITA Sec. 17h para 3].    "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","SUB","_Z",2019,"The rules contain a substance exclusion as from 1.1.2008, to be in line with the ECJs Cadbury judgment. This exemption from the general rule applies to income from a foreign legal entity that is resident within the European Economic Area (EEA), if the shareholder can prove that the foreign entity is established in the other country for business reasons and is engaged in real economic activities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","SUB","_Z",2024,"Under the general rule, the income of a controlled foreign entity is deemed to be subject to low taxation if it is not taxed at all or is subject to tax that is lower than 11,33 % (55% of the Swedish tax rate of 20,6 %. for income year 2024). However, income is not considered to be subject to low taxation if the foreign legal entity is a tax resident, and liable to income tax, in one of the countries listed in a white list, provided that the income in question has not been expressly excluded in the list. In addition, the CFC regime does not apply to income derived from a foreign legal entity engaged in international shipping activities, provided that also the shareholder is engaged in shipping activities, whether directly or indirectly through a legal person resident in the EEA."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","EXE","_Z",2024,"For the companies participating in the capital of joint stock and limited liable companies whose legal and business headquarters are not located in Türkiye, participation profits of these companies obtained from these subsidiaries that meet the conditions listed in Article 5/1-b of Law No. 5520 are exempt from Corporate Income Tax."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","YEAR","_Z",2019,"2006"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TUR","A","YEAR","_Z",2024,"2006"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MNE","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CMR","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CMR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CRI","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CRI","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CYM","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CYM","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DOM","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DOM","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","EXE","_Z",2024,"A foreign person is not deemed a CFC if there is real economic substance (i.e. adequate personnel, equipment, assets, and location to effectively carry out business activities) attributable to that person.        This condition is deemed to be fulfilled where the income from specified activities pursued with the entity’s/PE’s own assets and employees amount to at least 50% of its total income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","DEF","_Z",2019,"A CFC is defined as a company resident outside of Ireland that is controlled by an Irish resident company. An Irish resident company is considered to have control of a non-resident subsidiary where (in broad terms) it has direct or indirect ownership of or entitlement to more than 50% of the share capital, voting power or distributions."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","DEF","_Z",2024,"Section 835I defines \"chargeable income\" as meaning 'the undistributed income of a controlled foreign company which is subject to a controlled foreign company charge'. Undistributed income means the distributable profits for the accounting period of a CFC less any relevant distribution. The full definition is set out in section 835Q.  Under section 835R, the amount of undistributed income that the CFC charge can arise on is the portion included in the accounting profits of the company available for distribution that is attributable to the relevant Irish activities i.e. Irish SPFs, where those SPFs were instrumental in generating the income and the arrangements involving the SPFs were non-genuine (i.e. the CFC would not have owned the assets nor borne the risks that it did were it not for the Irish SPFs). A CFC charge will therefore arise if those arrangements were non-genuine and were put in place for the essential purpose of avoiding tax.."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","EXE","_Z",2019,"Not applicable."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","EXE","_Z",2024,"Yes. The CFC rules do not apply, if the controlled company (i) is resident in a treaty country and its income is not mainly financial income, or (ii) is resident in a country within the EEA and is engaged in business activities there and the Icelandic tax authorities are able to request all necessary information according to an international treaty."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","DEF","_Z",2019,"Under the CFC regime in Israeli tax law, an Israeli company or individual may be taxed on a proportion of certain undistributed profits of certain Israeli-controlled, non-resident companies in which the Israeli shareholder has a controlling interest (10% or more of any of the CFC’s ‘means of control’)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","DEF","_Z",2024,"Under the CFC regime in Israeli tax law, an Israeli company or individual may be taxed on a proportion of certain undistributed profits of certain Israeli-controlled, non-resident companies in which the Israeli shareholder has a controlling interest (10% or more of any of the CFC’s ‘means of control’)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","EXE","_Z",2019,"The income to be taxed under the CFC rule shall be determined in accordance with Regulation 23F of the Income Tax Regulations 1996. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MYS","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MYS","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","SUB","_Z",2019,"See question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","SUB","_Z",2019,"There is a de minimis rule if less than 5% of income is attributed income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","SUB","_Z",2024,"A CFC is not required to attribute income if its passive income is less than 5% of total gross income. (CFCs in the same country can apply the 5% test at a consolidated level if certain conditions are met)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PNG","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PNG","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","YEAR","_Z",2019,"2015"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","YEAR","_Z",2024,"2015"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","YEAR","_Z",2019,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","YEAR","_Z",2024,"1995"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","QAT","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","QAT","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","YEAR","_Z",2019,"2018"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","YEAR","_Z",2024,"2018"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","DEF","_Z",2019,"A CFC is any foreign corporation if more than 50% of the total combined voting power of all classes of stock of such corporation entitled to vote or the total value of the stock of such corporation is owned directly or indirectly by United States shareholders (U.S. shareholder) on any day during the taxable year of such foreign corporation. A U.S. shareholder is defined as a United States person (U.S. person) who owns 10 percent or more of the vote or value of all classes of stock of a corporation. Constructive ownership rules can attribute foreign stock ownership of one person to a related person."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","USA","A","DEF","_Z",2024,"  \t\t  A CFC is any foreign corporation if more than 50% of the total combined voting power of all classes of stock of such corporation entitled to vote or the total value of the stock of such corporation is owned directly or indirectly by United States shareholders (U.S. shareholder) on any day during the taxable year of such foreign corporation. A U.S. shareholder is defined as a United States person (U.S. person) who owns 10 percent or more of the vote or value of all classes of stock of a corporation. Constructive ownership rules can attribute foreign stock ownership of one person to a related person.       "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VNM","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","VNM","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","DEF","_Z",2019,"CFC rules apply where more than 50% of the participation or voting rights in a foreign company are directly or indirectly exercisable by South African residents. The rules are partially relaxed in relation to listed companies.  Foreign companies include protected cell companies, which means they include foreign companies held via trusts or foundations, if such companies are consolidated by a South African resident company under IFRS10."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","DEF","_Z",2024,"CFC rules apply where more than 50 per cent of the total participation rights in that foreign company are directly or indirectly held, or more than 50 per cent of the voting rights in that foreign company are directly or indirectly exercisable, by one or more persons that are South African residents. The rules are partially relaxed in relation to voting rights in listed foreign companies.\nCFC net income to be included in the South African resident's income is based on the ratio of the participation rights of that resident in relation to that CFC's total participation rights. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ABW","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ABW","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AGO","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AGO","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","EXE","_Z",2019,"Certain exemptions provided for non-portfolio dividends (10% or more); 1) sale of a CFC interest. Further, where CFCs are located in a listed country (US, UK, Canada, France, Germany, NZ, Japan) only particular types of income (referred to as Eligible Designated Concession Income) is attributable to the Australian controller. 2) There is also an AFI subsidiary exemption which enables interest and certain asset and currency transactions to be exempt for CFCs that are subsidiaries of a registered Australian AFI (may be broader than Australian banks)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","EXE","_Z",2024,"Yes - active income test (less than 5% of income is from passive income, tainted sales, tainted services). Generally, if the CFC satisfies the 'active income test' then there is no need to attribute income from that CFC to its Australian controllers."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","EXE","_Z",2019,"No limitation in function of the size of the participation. No foreign tax credit. But when the CFC distributes profits that have already been subject to tax at the level of the Belgian corporate shareholder, based on the Belgian CFC-rules, these profits shall be fully deducted from the recipient's tax base."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BEL","A","EXE","_Z",2024,"The CFC rules do not apply when:\n- less than 1/3 of the total income qualifies as passive income;\n- the CFC is a financial enterprise and its passive income comes for one-third or less from transactions with the taxpayer or with the taxpayer's associated entities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","EXE","_Z",2019,"Tax Rate Exemption : ETR 50% compared with Czech"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","EXE","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","SUB","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","SUB","_Z",2019,"There are exclusions based on substantial activities and reasonable reasons for establishing in a country."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","EXE","_Z",2019,"As of January 1, 2019, there are two CFC rules in Estonia:  1) CFC rule from the ATAD Directive applicable to companies; 2) CFC rule applicable to natural persons. ATAD CFC rule is not applicable to an entity or permanent establishment with accounting profits of no more than EUR 750 000, and non-trading income of no more than EUR 75 000. In case of CFC rule applicable to natural persons, CFC's income is taxed in Estonia if CFC is located in a low tax rate territory. A low tax rate territory is a foreign state or a territory with an independent tax jurisdiction in a foreign state, which does not impose a tax on the profits earned or distributed by a legal person or where such tax is less than one-third of the income tax which a natural person who is an Estonian resident would have to pay on a similar amount of business income. There is a white list of the jurisdictions that are not considered to be a low tax rate territory. This list includes all Estonian tax treaty partners."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","EXE","_Z",2024,"As of January 1, 2019, there are two CFC rules in Estonia:        1) CFC rule from the ATAD Directive applicable to companies;    2) CFC rule applicable to natural persons. ATAD CFC rule applies only in case of CFC’s income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company's income.        In case of CFC rule applicable to natural persons, there is an exemption for a CFC if more than 50 per cent of its annual income is derived from actual economic activity or if the state or territory of location of the legal person provides the Estonian tax authority with information concerning the income of a person controlled by Estonian residents."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRD","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRD","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","YEAR","_Z",2019,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","YEAR","_Z",2024,"1997"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","YEAR","_Z",2019,"2019 (ATAD)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IRL","A","YEAR","_Z",2024,"2019 (ATAD)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","DEF","_Z",2019,"CONTROL TEST: When the taxpayer has the effective control or control of the administration of the foreign entity (to the extent, that he can decide the moment of the distribution of income or dividends, either directly or through another person) by reason of an average participation per day in the foreign entity. As an anti-fragmentation rule, it is required to add up the average participation per day of related parties and closely-related-individuals regardless where they reside.  OTHER: It applies to foreign legal entities, transparent entities and any kind of arrangement. It does not apply to PEs held directly by the Mexican taxpayer, since the income of such PEs should be accrued by the Mexican taxpayer by reason of other chapters of the law."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MEX","A","DEF","_Z",2024,"CONTROL TEST: When the taxpayer has the effective control or control of the administration of the foreign entity (to the extent, that he can decide the moment of the distribution of income or dividends, either directly or through another person) by reason of an average participation per day in the foreign entity. As an anti-fragmentation rule, it is required to add up the average participation per day of related parties and closely-related-individuals regardless where they reside.        OTHER: It applies to foreign legal entities, transparent entities and any kind of arrangement. It does not apply to PEs held directly by the Mexican taxpayer, since the income of such PEs should be accrued by the Mexican taxpayer by reason of other chapters of the law."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MSR","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MSR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","DEF","_Z",2019,"Portuguese definition of CFC (see article 66, CITC): Profits or incomes of non-residents in Portugal and submitted to clearly more favourable tax regime are treated (with appropriate deductions) as profits or incomes of companies with residence in Portugal that, directly or indirectly, have at least 25% of capital, voting rights, rights on profits or incomes or rights on assets of said non-residents companies. A non-resident company is considered submitted to a clearly more favourable tax regime if the residence jurisdiction is by law considered has such or if that company pays an effective CIT or equivalent lower than 50% of the Portuguese one."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","DEF","_Z",2024,"  \t\t  Portuguese definition of CFC (see article 66, CITC): Profits or incomes of non-residents in Portugal and submitted to clearly more favourable tax regime are treated (with appropriate deductions) as profits or incomes of companies with residence in Portugal that, directly or indirectly, have at least 25% of capital, voting rights, rights on profits or incomes or rights on assets of said non-residents companies. A non-resident company is considered submitted to a clearly more favourable tax regime if the residence jurisdiction is by law considered has such or if that company pays an effective CIT or equivalent lower than 50% of the Portuguese one.       "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","EXE","_Z",2019,"The following shall not be considered controlled foreign companies according to the provisions of the law: a) the entity or the permanent establishment, if this registers in a fiscal period incomes from the categories mentioned by the law, representing one third or less than one third of the total incomes recorded in the calculated fiscal period; b) the financial enterprise which records in a fiscal period incomes of the nature provided in the law arising out of operations performed with the Romanian taxpayer or its associated enterprises, representing one third or less than one third of the total incomes registered by the financial undertaking."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","EXE","_Z",2024,"  \t\t  The provisions of CFC rules shall not apply if the controlled foreign company has its fiscal residence or is located in a Member State / third country which is a party to the EEA Agreement and carries out a significant economic activity, supported by personnel, equipment, assets and spaces, as evidenced by the relevant facts and circumstances.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SMR","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SMR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","DEF","_Z",2019,"CFC rules will generally apply if: taxpayer directly or indirectly holds more than 50% of capital or voting rights or an entitlement to the profits of a foreign entity, which is not subject to tax under CITA and foreign entity's tax paid is less than 50% of the tax that would have been paid under Slovenian CITA."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVN","A","DEF","_Z",2024,"CFC rules will generally apply if: taxpayer directly or indirectly holds more than 50% of capital or voting rights or an entitlement to the profits of a foreign entity, which is not subject to tax under CITA and foreign entity's tax paid is less than 50% of the tax that would have been paid under Slovenian CITA."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TTO","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","TTO","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARE","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARE","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARG","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARM","A","CFC","_Z",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ARM","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUS","A","SUB","_Z",2019,"Yes - active income test (less than 5% of income is from passive income, tainted sales, tainted services). Generally, if the CFC satisfies the 'active income test' then there is no need to attribute income from that CFC to its Australian controllers."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DEU","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HTI","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HTI","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HUN","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","DEF","_Z",2019,"A controlled foreign taxable subject (i.e. CFC) means: 1) a controlled foreign taxable entity; 2) a permanent establishment of a Lithuanian entity whose income is not attributable to the tax base of the Lithuanian entity.  A controlled foreign taxable entity means a foreign entity where a Lithuanian entity alone or together with associated persons on the last date of the tax period of this foreign entity directly or indirectly owns more than 50 % of shares (interests, member shares), voting rights or rights to the share of distributable profits or exclusive rights to purchase them.  The income of the CFC is taxed only if: 1) a CFC is registered or otherwise organised in the target territory (blacklisted jurisdiction); or 2) passive income of the CFC exceeds 1/3 of total income of this CFC during the tax period; and 3) actual corporate income tax paid on income of the CFC following the rules on corporate income tax or equivalent tax applied in this foreign state is lower than 50 % of actual corporate income tax on income of CFC which would have been computed following the Lithuanian CFC rules. For the purpose of this paragraph, CFC income includes only passive income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","DEF","_Z",2024,"A controlled foreign taxable subject (i.e. CFC) means:    1) a controlled foreign taxable entity;    2) a permanent establishment of a Lithuanian entity whose income is not attributable to the tax base of the Lithuanian entity.        A controlled foreign taxable entity means a foreign entity where a Lithuanian entity alone or together with associated persons on the last date of the tax period of this foreign entity directly or indirectly owns more than 50 % of shares (interests, member shares), voting rights or rights to the share of distributable profits or exclusive rights to purchase them.        The income of the CFC is taxed only if:    1) a CFC is registered or otherwise organised in the target territory (blacklisted jurisdiction); or    2) passive income of the CFC exceeds 1/3 of total income of this CFC during the tax period; and    3) an actual corporate tax of the CFC calculated of the income of that CFC according to the rules of corporate tax or similar tax applicable in that foreign state is lower than 50 per cent of an actual corporate tax which would have been calculated of the income of that CFC according to the provisions of  Law on Corporate Income Tax. For the purposes of this item, no account shall be taken of the income that has been earned by the CFC through a permanent establishment in another foreign state which is not taxed in a foreign state where the CFC is registered or otherwise organised.  For the purpose of this paragraph, CFC income includes only passive income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","YEAR","_Z",2019,"2004"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","YEAR","_Z",2024,"2003"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","DEF","_Z",2019,"A CFC is a foreign entity or foreign permanent establishment, the income of which is not taxable or is exempt in Luxembourg. In the case of a foreign entity, there must be a Luxembourg resident (either alone or with associated enterprises) that directly or indirectly holds more that 50% of the voting rights or capital, or is entitled to more that 50% of the profits. In addition, the income tax paid by the foreign entity or foreign permanent establishment must be lower than the income tax it would have paid on those profits if it were subject to tax in Luxembourg."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","DEF","_Z",2024,"A CFC is a foreign entity or foreign permanent establishment, the income of which is not taxable or is exempt in Luxembourg.    In the case of a foreign entity, there must be a Luxembourg resident (either alone or with associated enterprises) that directly or indirectly holds more that 50% of the voting rights or capital, or is entitled to more that 50% of the profits.    In addition, the income tax paid by the foreign entity or foreign permanent establishment must be lower than the difference between the income tax it would have paid on those profits if it were subject to tax in Luxembourg and the income tax paid by the foreign entity or foreign permanent establishment"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","YEAR","_Z",2019,"2013 - for natural persons. 2019 - for companies"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","YEAR","_Z",2024,"2013 - for natural persons    2019 - for companies  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MNG","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MNG","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","EXE","_Z",2019,"There are the following CFC exemptions: 1.- The total passive income is equal or less than 20% of the total CFC´s income. 2.- The total passive income is equal or less than US$ 6,360 approximately (5 Tax Unit). 3.- Peruvian source income, except for the income generated by CFC as a result of transactions carried out with domiciled taxpayers in the country, provided that: (i) they are related parties, (ii) such income constitutes a deductible expense for the domiciled taxpayers, and (iii) such income constitutes Peruvian source income subjects to a Tax rate of less than 30%."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","EXE","_Z",2024,"There are the following CFC exemptions:\n1.- The total passive income is equal or less than 20% of the total CFC´s income.    \n2.- The total passive income is equal or less than US$ 6,360 approximately (5 Tax Unit).    \n3.- Peruvian source income, except for the income generated by CFC as a result of transactions carried out with domiciled taxpayers in the country, provided that: \n(i) they are related parties, \n(ii) such income constitutes a deductible expense for the domiciled taxpayers, and\n (iii) such income constitutes Peruvian source income subjects to a Tax rate of less than 30%.\n4) such income does not constitute income from a Peruvian source, among others."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MRT","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","SUB","_Z",2019,"The CFC rules do not apply where the CFC carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances (Article 7 paragraph 2 point a ATAD). The exemption is applicable to CFC located in an EU-Member State as well as for CFC located in a third country that is not party to the EEA Agreement."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","SUB","_Z",2024,"Austria opted to implement the two exemptions stipulated in Article 7 paragraph 3 ATAD 1."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","YEAR","_Z",2019,"1976"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CAN","A","YEAR","_Z",2024,"1976"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","DEF","_Z",2019,"The taxpayer by itself, or together with its associated enterprises holds a participation equal or more than 50 percent of capital, voting rights or outcome. Also the actual corporate tax paid on its profits by the entity is lower than a 75 percent of the corporate tax that would have been charged on the entity under the corporate tax system of Spain."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","DEF","_Z",2024,"The taxpayer by itself, or together with its associated enterprises holds a participation equal or more than 50 percent of capital, voting rights or outcome. Also the actual corporate tax paid on its profits by the entity is lower than a 75 percent of the corporate tax that would have been charged on the entity under the corporate tax system of Spain."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ESP","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRO","A","CFC","_Z",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRO","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRL","A","DEF","_Z",2024,"A Greenlandic resident parent company is subject to taxation of CFC income, if the parent company directly or indirectly controls more than 50 % of shares or voting rights in a company in a jurisdiction with a significant lower effective tax rate than Greenland (<3/4) and that at least 10 % of subsidiarys assets stems from financial assets."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","YEAR","_Z",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","DEF","_Z",2019,"Controlled foreign company rule (implementation of ATAD 1 from 2019)  Croatian Tax Administration shall treat an entity, or a permanent establishment of which the profits are not subject to tax or are exempt from tax in other Member State of the EU, as a controlled foreign company where the following conditions are met: (a) in the case of an entity, the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity;"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","DEF","_Z",2024,"Controlled foreign company rule (implementation of ATAD 1 from 2019)        Croatian Tax Administration shall treat an entity, or a permanent establishment of which the profits are not subject to tax or are exempt from tax in other Member State of the EU, as a controlled foreign company where the following conditions are met: (a) in the case of an entity, the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity;"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LIE","A","EXE","_Z",2019,"n/a"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","EXE","_Z",2019,"The rules do not apply to a CFC that has profits that do not exceed €750,000 or do not exceed 10% of its operation costs in the period."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LUX","A","EXE","_Z",2024,"The rules do not apply to a CFC that has profits that do not exceed €750,000 or do not exceed 10% of its operation costs in the period."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MDV","A","SUB","_Z",2024," 1. Taxpayers are required to submit schedule 5, Reporting of share of taxable income from Controlled Foreign Entities, if they are a resident of the Maldives and hold 10% or more in the share capital of a controlled foreign entity as specified in Section 70 of the Income Tax Act.\n2.  Txapayers who hold more than 10% in the share capital of more than one Controlled Foreign Entity must submit schedule 5 for each\nof such entity separately."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MLT","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","DEF","_Z",2019,"Control (>50%)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","DEF","_Z",2024,"Control (>50%)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAK","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PAK","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","DEF","_Z",2019,"An entity shall be treated as a controlled foreign company if the following conditions are cumulatively met: a) the taxpayer, alone or together with its associated enterprises, holds a direct or indirect holding of more than 50% of the voting rights or directly or indirectly owns more than 50% of the capital of the entity or is entitled to receive more than 50% of that entity&#39;s profits; b) the tax on profits actually paid for its profits by the entity or permanent establishment is less than the difference between the profit tax that would have been levied from the entity or the permanent establishment, calculated in accordance with the provisions regarding to the tax on profit from Fiscal Code of this Title and the profit tax actually paid for its profits by the entity or by the permanent establishment. For the purposes of this letter, the permanent establishment of an entity treated as a foreign controlled company shall not be taken into account in so far as the head office is not subject to taxation or is exempt from tax in the jurisdiction of the controlled foreign company."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","DEF","_Z",2024,"  \t\t  An entity shall be treated as a controlled foreign company if the following conditions are cumulatively met: \na) the taxpayer, alone or together with its associated enterprises, holds a direct or indirect holding of more than 50% of the voting rights or directly or indirectly owns more than 50% of the capital of the entity or is entitled to receive more than 50% of that entity's profits; \nb) the tax on profits actually paid for its profits by the entity or permanent establishment is less than the difference between the profit tax that would have been levied from the entity or the permanent establishment, calculated in accordance with the provisions regarding to the tax on profit from Fiscal Code of this Title and the profit tax actually paid for its profits by the entity or by the permanent establishment. For the purposes of this letter, the permanent establishment of an entity treated as a foreign controlled company shall not be taken into account in so far as the head office is not subject to taxation or is exempt from tax in the jurisdiction of the controlled foreign company.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SLE","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SLE","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","UKR","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","UKR","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","DEF","_Z",2019,"Definition of CFC:If the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity (Art. 7 paragraph 1 ATAD); and the actual corporate tax paid on its profits by the entity or permanent establishment does not surpass 12.5%."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","DEF","_Z",2024,"Definition of CFC income: Interest or any other income generated by financial assets; \nroyalties or any other income generated from intellectual property; \ndividends and income from the disposal of shares, if these would be a subject to tax at the participating corporation;\nincome from financial leasing; \nincome from insurance, banking and other financial activities; \nincome from invoicing companies that earn sales and services income from goods and services purchased from and sold to associated enterprises, and add no or little economic value; \nThe income of the CFC is to be determined in accordance with the Austrian tax law."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BLZ","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BLZ","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHN","A","YEAR","_Z",2019,"2008"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHN","A","YEAR","_Z",2024,"2008"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","SUB","_Z",2019,"Yes, active income and dividends attributable to active income in the CFC are excluded."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CPV","A","CFC","_Z",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CPV","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DMA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","DMA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EGY","A","SUB","_Z",2024,"None"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","SUB","_Z",2019,"There are two series of exemptions :  - Inside the EU, the foreign entity established in a member State will not be subject to the CFC rules, unless  the French tax authorities demonstrate that the foreign entity located in another EU country constitutes an artificial arrangement, set up to circumvent French tax legislation ;  -In other cases, if a French company falls within the scope of CFC, it can be exempted if it demonstrates that the operations of the entity established outside France are primarily intended to have an object and effect other than to transfer profits in a State or territory where it is subject to a preferential tax regime.This condition is deemed to be fulfilled when the entity established outside France has mainly an industrial or commercial activity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","SUB","_Z",2024,"CFC rules, in principle, are not applicable with respect of foreign branches or subsidiaries located in another EU country. However, this exception is not applicable if the French tax authorities can demonstrate that the foreign entity located in another EU country constitutes an artificial arrangement, set up to circumvent French tax legislation. This concept is similar to the ‘abuse of law’ concept, although it does not have all the same characteristics.\nIn other cases, if a French company falls within the scope of CFC, it can be exempt if it demonstrates that the operations of the entity established outside France are primarily intended to have an object and effect other than to transfer profits in a State or territory where it is subject to a preferential tax regime.                         This condition is deemed to be fulfilled when the entity established outside France has mainly an industrial or commercial activity.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GGY","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GGY","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","EXE","_Z",2019,"As mentioned above (question 4) companies of which the main class of shares of which are traded on a regulated market are excluded (i.e. listed companies are excluded)."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","EXE","_Z",2024,"CFC rules do not apply where the controlled foreign company carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances. The above does not apply where the controlled foreign company is resident or situated in a third country that is not party to the EEA Agreement.\n\nCFC rules do not apply in cases where the legal person or entity is resident for tax purposes in an EU member state, unless the establishment or financial activity of the legal person or entity constitutes a fictitious arrangement made essentially with the intention to avoid the applicable tax. In case the legal person or entity is resident for tax purposes in a country which is a party to the EEA agreement and an information exchange agreement is in force and implemented commensurate with the exchange of information upon request provided in Directive 2011/16/EU, CFC rules do not apply, unless the establishment or financial activity of the legal person or entity constitutes a fictitious arrangement made essentially with the intention to avoid the applicable tax."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","YEAR","_Z",2019,"2014"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRC","A","YEAR","_Z",2024,"2014; amended since 2019 by COUNCIL DIRECTIVE (EU) 2016/1164"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRL","A","CFC","_Z",2019,"NA"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GRL","A","SUB","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IMN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IMN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","DEF","_Z",2019,"A CFC is a non-resident company, fund, institution or other entity in a low-tax country that is at least 50% owned or controlled, directly or indirectly, by resident taxpayers."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","DEF","_Z",2024,"A CFC is a non-resident company, fund, institution or other entity in a low-tax country that is at least 50% owned or controlled, directly or indirectly, by resident taxpayers."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LTU","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MDV","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MDV","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","SUB","_Z",2019,"substantive economic activity supported by staff, equipment, assets and premises"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ROU","A","SUB","_Z",2019,"The provisions of CFC rules shall not apply if the controlled foreign company has its fiscal residence or is located in a Member State / third country which is a party to the EEA Agreement and carries out a significant economic activity, supported by personnel, equipment, assets and spaces, as evidenced by the relevant facts and circumstances."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SAU","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SAU","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","YEAR","_Z",2019,"2018, with effect in 2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SVK","A","YEAR","_Z",2024,"2018, with effect in 2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","EXE","_Z",2019,"Under the general rule, the income of a controlled foreign entity is deemed to be subject to low taxation if it is not taxed at all or is subject to tax that is lower than 12,1% (55% of the Swedish tax rate of 22%. for income year 2018). However, income is not considered to be subject to low taxation if the foreign legal entity is a tax resident, and liable to income tax, in one of the countries listed in a white list\u009d, provided that the income in question has not been expressly excluded in the list. In addition, the CFC regime does not apply to income derived from a foreign legal entity engaged in international shipping activities, provided that also the shareholder is engaged in shipping activities, whether directly or indirectly through a legal person resident in the EEA."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","SWE","A","EXE","_Z",2024,"The rules contain a substance exclusion as from 1.1.2008, to be in line with the ECJs Cadbury judgment. This exemption from the general rule applies to income from a foreign legal entity that is resident within the European Economic Area (EEA), if the shareholder can prove that the foreign entity is established in the other country for business reasons and is engaged in real economic activities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","THA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","THA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","EXE","_Z",2019,"Key exemptions, exclusions and relief measures include the following: a) residents who together with connected parties hold less than 10% of the participation and voting rights b)a high tax exemption where the taxes payable in a foreign jurisdiction at least equal 75% of the South African taxes which would have payable had the foreign resident been a South African resident. c) certain companies falling under the headquarter company rules. d) income or taxable income which is already taxed in South Africa. e) relief from foreign taxes paid by the CFC."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ZAF","A","EXE","_Z",2024,"High-tax exemption:\nthe net income of the CFC is deemed to be nil if the income tax paid to another government is at least 67,5% of the amount of normal tax that would have been payable on taxable income of the CFC in South Africa (i.e. if the statutory tax rate is more than 18,2% (27% x 67,5%). "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NAM","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BFA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BFA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","DEF","_Z",2019,"As of January 1, 2019, there are two CFC rules in Estonia:  1) CFC rule from the ATAD Directive applicable to companies; 2) CFC rule applicable to natural persons. In case of ATAD CFC rule, CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. In case of CFC rule applicable to natural persons, a legal person is deemed to be controlled by Estonian residents if one or several legal or natural persons who are Estonian residents own at least 50 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons.  The income of a foreign legal person is deemed to be the taxable income of a resident natural person if the condition prescribed above is fulfilled and the resident owns at least 10 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","DEF","_Z",2024,"As of January 1, 2019, there are two CFC rules in Estonia:        1) CFC rule from the ATAD Directive applicable to companies;    2) CFC rule applicable to natural persons. In case of ATAD CFC rule, CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. In case of CFC rule applicable to natural persons, a legal person is deemed to be controlled by Estonian residents if one or several legal or natural persons who are Estonian residents own at least 50 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons.        The income of a foreign legal person is deemed to be the taxable income of a resident natural person if the condition prescribed above is fulfilled and the resident owns at least 10 per cent of the shares, votes or rights to the profits of the legal person directly or together with associated persons."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","YEAR","_Z",2019,"2000"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","EST","A","YEAR","_Z",2024,"2000"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","DEF","_Z",2019,"A foreign company is a CFC when UK persons hold more than a 50% interest in that company, by reference to legal control, economic control, or accounting standards. A separate test applies to joint ventures."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","DEF","_Z",2024,"A foreign company is a CFC when UK persons, together with related persons in the UK or elsewhere,  hold more than a 50% interest in that company, by reference to legal control, economic control, or accounting standards. A separate test applies to joint ventures. CFC income is computed on basis of UK corporate tax rules, with separate charging provisions for trading income, non-trade finance profits and trading finance profits."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","YEAR","_Z",2019,"1984 new regime introduced in 2013"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","GBR","A","YEAR","_Z",2024,"2013 (original CFC regime introduced in 1984)"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","EXE","_Z",2019,"The situation in which the rules do not apply is when the CFC’s shares are listed on a recognised stock exchange."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","EXE","_Z",2024,"Foreign entities whose shares are listed on a recognised stock exchange are excluded. Incomes other than passive income (dividend, interest, royalty, capital gain, and rent from land and building) are excluded. Interest income derived by CFC that is controlled by banking taxpayers is excluded. Dividend income derived by CFC from other CFC is excluded."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","SUB","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","IDN","A","SUB","_Z",2024,"Indonesian taxpayers are deemed to have control over non-listed foreign entities if they own at least 50% of ownership or if they own at least 50% of ownership collectively with other Indonesian taxpayers.\nThe ownership used to determine the CFC status is the ownership percentage at the end of the Indonesian taxpayer’s fiscal year, based on either the percentage of paid-up capital or the percentage of paid-up capital with voting rights.\nCFC rules also apply to trust and other similar foreign entities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","EXE","_Z",2019,"Effective tax rate that does not exceed 15%"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","EXE","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","EXE","_Z",2019,"1 Exemption for the full inclusion (1) Specified CFCs (i.e. Cash Box, Paper Company and Black-List Company) : effective tax rate of a CFC greater than or equal to 30% (2) Other CFCs : effective tax rate of a CFC greater than or equal to 20% 2 Exemption for the passive income inclusion (1) Effective tax rate of a CFC greater than or equal to 20% (2) Either passive income less than or equal to JPY 20 million, or passive income per profits before tax ratio less than or equal to 5%"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","EXE","_Z",2024,"Yes, we have the Economic Activity Tests."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KAZ","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KAZ","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MAC","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MAC","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","DEF","_Z",2019,"The CFC rule has been introduced in Mauritius in Section 90A of the Income Tax Act 1995 with effect from 01 July 2019 as an anti-avoidance provision. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MUS","A","DEF","_Z",2024,"  \t\t  The CFC rule has been introduced in Mauritius in Section 90A of the Income Tax Act 1995 with effect from 01 July 2019 as an anti-avoidance provision.       "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NGA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NGA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","EXE","_Z",2019,"See question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NOR","A","EXE","_Z",2024,"See question 5."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NZL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","DEF","_Z",2019,"CFC is a non-domiciled entity that fulfils the following conditions:(i) It is treated as opaque. It is considered that companies, trusts, investment funds and partnerships always comply with this requirement. (ii) It is incorporated or established in a: non-cooperative or low-tax jurisdiction, or jurisdiction in which its passive income is not subject to an income tax, or jurisdiction in which the tax effectively paid for the entity's passive income is equal or less than 75% of the Peruvian tax which would be payable on the same income. (iii) Peruvian domiciled taxpayer alone or together with its Peruvian domiciled related parties owns directly or indirectly more than 50% of the capital, voting power or the profits of the entity. Options to acquire shares must be considered to determine the test control."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","DEF","_Z",2024,"CFC is a non-domiciled entity that fulfils the following conditions:(i) The entity must be different from its partners, associates, shareholders or, in general, the people who are part of it. (ii) It is incorporated or established, or is considered resident , in accordance with the rules of the State where any of these situations take place, in a country or territory: a. non-cooperative or low-tax jurisdiction, or b. jurisdiction in which its passive income is not subject to an income tax, or jurisdiction in which the tax effectively paid for the entity's passive income is equal or less than 75% of the Peruvian tax which would be payable on the same income. (iii) Peruvian domiciled taxpayer alone or together with its Peruvian domiciled related parties owns directly or indirectly more than 50% of the capital, voting power or the profits of the entity. Options to acquire shares must be considered to determine the test control."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","YEAR","_Z",2019,"2013"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PER","A","YEAR","_Z",2024,"2013"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","CFC","_Z",2019,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","POL","A","CFC","_Z",2024,"Yes"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","EXE","_Z",2019,"The CFC Portuguese rule is not applicable to non-resident companies of other EU member states or EEA member states. In this last case, the exemption operates only if the member state complies with administrative tax cooperation similar to the one of the EU and the taxpayer demonstrates that his company is submitted to valid substantive economic reasons and develops agricultural, industrial, commercial or services economic activities."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","PRT","A","EXE","_Z",2024,"  \t\t  Portuguese CFC rule is excluded if CFC undertakes substantial activities (agriculture or industry or, not predominantly in Portugal, commerce or services), being such activities the cause of at least 75% of his profits or incomes, and if in the CFC main activity are not included some well described operations, as credit, financial, insurance, holding and lease of goods ones with personnel, equipment, actives and installations.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","YEAR","_Z",2019,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","AUT","A","YEAR","_Z",2024,"2019"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRN","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BRN","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHE","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CHE","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","DEF","_Z",2019,"CFCs are those entities that: Are controlled by one or more Colombian tax residents, according to the terms in the new legislation, (an entity is controlled if it is a related party due to the presumptions of subordination contemplated under transfer pricing rules). Do not have their tax residency in Colombia. CFCs include investment vehicles such as corporations, trusts, collective investment funds, other fiduciary businesses and private interest foundations, incorporated with operation or domiciled abroad, regardless if they are considered to be legal entities or not, or if they are disregarded for tax purposes or not. If the entity is established in a non-cooperative or low-tax jurisdiction, control is presumed regardless of the level of participation or involvement of the Colombian resident in the entity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","COL","A","DEF","_Z",2024,"CFCs are those entities that: Are controlled by one or more Colombian tax residents, according to the terms in the new legislation, (an entity is controlled if it is a related party due to the presumptions of subordination contemplated under transfer pricing rules). Do not have their tax residency in Colombia. CFCs include investment vehicles such as corporations, trusts, collective investment funds, other fiduciary businesses and private interest foundations, incorporated with operation or domiciled abroad, regardless if they are considered to be legal entities or not, or if they are disregarded for tax purposes or not. If the entity is established in a non-cooperative or low-tax jurisdiction, control is presumed regardless of the level of participation or involvement of the Colombian resident in the entity."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","DEF","_Z",2019,"Control test : 50% basis"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","CZE","A","DEF","_Z",2024,"Control test : 50% basis"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","DEF","_Z",2019,"The CFC rules requires, under some circumstances, the taxation in France, in the hands of a  French corporation, of the profits of a foreign entity which it owns.There are both control and low taxation threshold requirements : - a French corporation falls within the scope of CFC if it owns directly or indirectly more than 50 per cent of the share or voting rights of a foreign entity (company, subsidiary, branches, trust or comparable entities) ;  This threshold is reduced to 5% when more than 50% of the shares, shares, financial rights or voting rights of the legal entity established or incorporated outside France are held by companies established in France which act in concert, when the foreign entity is listed on a regulated market, or by companies that are directly or indirectly placed in a situation of control or dependence with respect to the legal person established in France and the foreign entity benefits from a preferential tax regime in the foreign State. An entity is considered to benefit from a preferential tax regime if it is not taxable in that State or taxable at a level that is less than 40% or more than it would have paid under the french law if it had been located in France (the threshold of 40 % aplies from the 1st of 2020, before that date the 50 % threshold aplies. "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","FRA","A","DEF","_Z",2024,"The CFC rules requires, under some circumstances, the taxation in France, in the hands of a French corporation, of the profits of a foreign entity which it owns.                                                          There are both control and low taxation threshold requirements :     - a French corporation falls within the scope of CFC if it owns directly or indirectly more than 50 per cent of the share or voting rights of a foreign entity (company, subsidiary, branches, trust or comparable entities) ;  This threshold is reduced to 5% when more than 50% of the shares, shares, financial rights or voting rights of the legal entity established or incorporated outside France are held by companies established in France which act in concert, when the foreign entity is listed on a regulated market, or by companies that are directly or indirectly placed in a situation of control or dependence with respect to the legal person established in France and the foreign entity benefits from a preferential tax regime in the foreign State. An entity is considered to benefit from a preferential tax regime if it is not taxable in that State or taxable at a level that is less than 40% or more than it would have paid under the french law if it had been located in France (the threshold of 40 % applies from the 1st of January 2020, before that date the 50 % threshold applies).       "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","EXE","_Z",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HKG","A","SUB","_Z",2019,"Not applicable"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","HRV","A","SUB","_Z",2019,"(Yes) Controlled foreign company rule (implementation of ATAD 1 from 2019)  This point shall not apply where the controlled foreign company carries on a substantive economic activity supported by staff, equipment, assets and premises, as evidenced by relevant facts and circumstances."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISL","A","SUB","_Z",2019,"Yes. The CFC rules do not apply, if the controlled company (i) is resident in a treaty country and its income is not mainly financial income, or (ii) is resident in a country within the EEA and is engaged in business activities there and the Icelandic tax authorities are able to request all necessary information according to an international treaty."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","ISR","A","SUB","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","JPN","A","SUB","_Z",2019,"Yes, we have the Economic Activity Tests."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LKA","A","CFC","_Z",2019,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LKA","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","EXE","_Z",2019,"The CFC rule in the CIT Law is not applicable to an entity or permanent establishment with accounting profits of no more than EUR 750 000, and non-trading income of no more than EUR 75 000. However, this exclusion is not applicable for entity set or established in a low tax or no tax countries and territories."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","EXE","_Z",2024,"  \t\t  The CFC rule in the CIT Law   applies only in case of CFC’s income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company's income.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","SUB","_Z",2019,"The CFC rule in the CIT Law applies only in case of CFC&rsquo;s income arising from non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company&#39;s income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","LVA","A","SUB","_Z",2024,"  \t\t  The CFC rule in the CIT Law   is not applicable to an entity or permanent establishment with accounting profits of no more than EUR 750 000, and non-trading income of no more than EUR 75 000. However, this exclusion is not applicable for entity set or established in a low tax or no tax countries and territories.  "]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","MDV","A","DEF","_Z",2024,"The CFC apply when at least 10% of the ownership in a company, partnership, trust or other entity that is not a resident of the Maldives is controlled by 5 or fewer residents of the Maldives. The Maldives resident is required to include the share of taxable income of such foreign entity in its taxable income."]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","EXE","_Z",2019,"list of low tax jurisdictions"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","NLD","A","EXE","_Z",2024,"substantive economic activity supported by staff, equipment, assets and premises"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","BIH","A","CFC","_Z",2024,"No"]
["OECD.CTP.TPS:DSD_QDD_CFC@DF_QDD_CFC(1.0)","KWT","A","CFC","_Z",2024,"No"]