Interaction of Transfer Pricing Rules and CFC Provisions
Journal
Country
International
Published Date
Issue
International Transfer Pricing Journal 2016 (Volume 23), No. 5
Document
The author examines whether there is a need for both transfer pricing rules and CFC provisions, and what outcomes should be expected where these rules are applied concurrently. An analysis is provided of the structure known as the Double Irish with a Dutch Sandwich and the structure involving a so-called cash-box company in an operating lease arrangement. Moreover, the author considers (i) whether CFC rules can act as a backstop to transfer pricing rules and (ii) whether the application of these two sets of rules could lead to double taxation.