Table of Contents

Letter to the Minister of Finance

Press Statement by the Ministers of Finance and Revenue

Table of Contents

Chapter 1 – Introduction

1.1 Purpose of This Report
1.2 Submissions
1.3 Context of the Reforms
1.4 Criteria for Evaluation of Proposals
1.5 Objectives of International Tax Reform
1.6 Regimes Proposed in the Consultative Document
1.7 Summary: Main Building Blocks

Chapter 2 – Branch Equivalent Regime for Controlled Foreign Companies

2.1 Control Test
2.2 White List
2.3 Tax Preferences
2.4 Submissions
2.5 Dividends Received by a Controlled Company, Losses and Foreign Tax Credits

Chapter 3 – Foreign Investment Funds

3.1 Avoidance Problems: Need for an Alternative Regime
3.2 Coverage of the Regime
3.3 Foreign Investment Fund Regime

Chapter 4 – Treatment of Dividends

4.1 Corporate Recipient
4.2 Non-Corporate Recipient

Chapter 5 – Trusts

5.1 Introduction
5.2 Trust Income
5.3 Distributions From Resident Trusts
5.4 Distributions From Non-resident Trusts

Chapter 6 – Disclosure Requirements and Penalties

6.1 Disclosure Requirements and Penalties

Chapter 7 – Transitional Provisions

7.1 BE Regime
7.2 Resident Trusts
7.3 Non-Resident Trusts
7.4 Foreign Investment Funds
7.5 Recommendations

Chapter 8 – Further Measures

8.1 Role of a Capital Gains Tax
8.2 Interjurisdictional Allocation Rules
8.3 Recommendation

Chapter 9 – Summary and Conclusion

9.1 Summary of Recommendations
9.2 Conclusion

Annexes

1 Control Interests of Residents in Controlled Foreign Companies
2 Issues Relating to the Determination and Attribution of Branch Equivalent Income
3 Foreign Investment Funds
4 Trust regime
5 An Illustrative Transitional List of Low Tax Jurisdictions