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"Controlled Foreign Company Legislation", Rust (2019)

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Organized by the Institute for Austrian and International Tax Law Vienna, in cooperation with the Doctoral Program for International Business Taxation.

The conference focuses on Controlled Foreign Company (“CFC”) legislations. CFC rules as anti-abuse provisions have been increasingly gaining in importance. The format of the conference provides for a highly interactive environment in which reporters from all over the world will share their experience and research findings on how CFC rules are implemented in their jurisdictions, on the relationship between their CFC legislation and tax treaties/constitutional law/EU law, on the shortcomings of the current CFC rules and will provide recommendations on how to increase the effectiveness of their CFC legislation. The national reporters will address various aspects in relation to their CFC legislation. The discussion will start with an overview of the characteristics of the countries’ CFC legislation, including policy considerations and a legal analysis. Further on, reporters from EU-Member States will address the status of implementation of Art 7 and 8 Anti-Tax Avoidance Directive (ATAD) in their country. In addition, the reporters will give a critical analysis of their CFC legislation, providing insights to current flaws, potential improvements, additional compliance burdens arising from their application and the need to strike a balance between the mechanical nature of CFC rules and the effectiveness of more subjective anti-abuse provisions. Using the comparative approach in the analysis, we aim to provide the practical assessment of CFC rules as anti-abuse provisions, their effectiveness and their expected practical impact in the future.

The conference will be held from the evening of Thursday, July 4, to the evening of Saturday, July 6, 2019, in Rust, Burgenland, at Seehotel

We kindly invite researchers and practitioners in the area of international tax law and policy of any nationality to apply for participation. Please find the application form on our website for download.

Additionally we invite doctoral candidates in this field to apply for the doctorate workshop preceding the conference. The doctorate workshop will be held on Thursday July 4, from 15:00 to 18:00 (exact time still to be fixed) in Rust. Transportation can be organized.