On 3 April 2015, the OECD released a discussion draft for Action 3 (Strengthening CFC Rules) of the Base Erosion and Profiting Shifting (BEPS) Project.
This discussion draft considers all the constituent elements of CFC rules and breaks them down into the “building blocks” that are necessary for effective CFC rules. The majority of these building blocks include recommendations, and the building block that does not yet include a recommendation discusses possible options that could be included…