Tax regulation of controlled foreign companies: prerequisites for reform

The article discusses the main features of taxation of controlled foreign companies, as well as the prerequisites for reforming CFC rules in the context of the growing redistribution of capital to low-tax jurisdictions. The need for stricter measures in the tax regulation of CFC activities is caused by the abuse of tax benefits by controlling companies that reduce their tax burden by transferring significant amounts of capital from the country of residence abroad. The article describes the main methods of tax savings by using low-tax jurisdictions, as well as cites the reaction measures developed by the OECD to counteract these practices.