Keywords
tax avoidance
international taxation
deferral
How to Cite
Abstract
This article aims to analyze at a national and at an international level the institution of the CFC and its regulation also revising what has happened throughout history regarding its relationship with the international network of double taxation treaties, then there is an analysis of the new Chilean regulations regarding this figure and ends reviewing the eventual possibility that this legislation could be challenged because of possible elements of unconstitutionality.
References
AVI-YONAH, Reuven, Global Perspectives in Income Taxation Law, Nueva York, Oxford University Press, 2011.
AVI-YONAH, Reuven, International Tax as International Law, Nueva York, Cambridge University Press, 2007.
INTERNATIONAL FISCAL ASSOCIATION, Cahiers du Droit Fiscal, 2013 Vol. 98a, Copenhague.
MILLER, Angharad y OATS Lynne, Principles of International Taxation, 3ª ed., Londres, Bloomsbury Professional, 2012.
OECD Comitee on Fiscal Affairs, Harmful Tax Competition, París, OECD, 1998.
Attribution 4.0 International CC BY 4.0
You are free to:
- Share — copy and redistribute the material in any medium or format for any purpose, even commercially.
- Adapt — remix, transform, and build upon the material for any purpose, even commercially.
- The licensor cannot revoke these freedoms as long as you follow the license terms.
Under the following terms:
- Attribution — You must give appropriate credit , provide a link to the license, and indicate if changes were made . You may do so in any reasonable manner, but not in any way that suggests the licensor endorses you or your use.
- No additional restrictions — You may not apply legal terms or technological measures that legally restrict others from doing anything the license permits.
Notices:
You do not have to comply with the license for elements of the material in the public domain or where your use is permitted by an applicable exception or limitation .
No warranties are given. The license may not give you all of the permissions necessary for your intended use. For example, other rights such as publicity, privacy, or moral rights may limit how you use the material.