On 5 May 2015, the OECD published comments received in response to the public discussion draft on the Base Erosion and Profit Shifting (BEPS) Project Action 3: Strengthening CFC Rules.
The Action 3 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 discusse…