BEPS Action 3: Neutralising the effects of hybrid mismatch arrangements
- Ankit Jain
- Oct 12, 2021
- 1 min read
Action 3 aims to address BEPS by designing effective controlled foreign company (CFC) rules. CFCs provide opportunities for profit shifting and long-term deferral of taxation where the taxpayers establish non-resident affiliates to which they shift income.


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