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