Examples of using Controlled foreign in English and their translations into Hungarian
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A Controlled Foreign Corporation( CFC).
Most of these firms became CFCs, or controlled foreign corporations.”.
The Controlled Foreign Corporation status is complicated and knowing whether you must report your income as a shareholder in a CFC is tricky.
Ltd is a newly established and fully controlled foreign company in China by KION Group in Germany.
If more than 50 percent of the stock is owned by U.S. shareholders,the corporation is considered a controlled foreign corporation(CFC).
People also translate
Domestically controlled foreign affiliates(Outward FATS).
The same directive is also driving the standardization of Controlled Foreign Company(CFC) regulations.
CFC means, controlled Foreign Corporation.
Income recognised as dividend received in the targetyear reduce the tax base unless it originated from a controlled foreign company.
Where an entity or permanent establishment is treated as a controlled foreign company under paragraph 1, the Member State of the taxpayer shall include in the tax base.
If you, along with other US persons, own more than 50% of a foreign corporation,it is then defined as a Controlled Foreign Corporation(CFC).
The taxpayer mustprove that the company does not qualify as controlled foreign company, however, the indirect beneficial owner status is not to be proven by the taxpayer.
The member state of a taxpayer shall treat an entity, or a permanent establishment of which the profits are not subject to tax orare exempt from tax in that member state, as a controlled foreign company where the following conditions are met.
Another change is that aforeign person does not qualify as a controlled foreign company if the statutory shareholding exists in most of the taxable period of the resident taxpayer.
The category of Controlled Foreign Corporation was created to gather information on the income from foreign corporations controlled by U.S. citizens and to collect tax on that income.
Already this year, the rule that small business tax liability is terminated andnot optional if the taxpayer has a controlled foreign company or if its financing costs exceed a certain level has entered into force.
A foreign company qualified as the controlled foreign company of the Hungarian company if the Hungarian company has at least 50% stake in the foreign company or its profit share is more than 50%.
Where, under the rules of a Member State, the tax base of a taxpayer is calculated in accordance with point(a) of paragraph 2, the Member State mayopt not to treat financial undertakings as controlled foreign companies if one third or less of the entity's income from categories under point(a) of paragraph 2 comes from transactions with the taxpayer or its associated enterprises.
Financial undertakings shall not be treated as controlled foreign companies under paragraph 1 where not more than one third of the income accruing to the entity or permanent establishment from categories(a) to(f) of paragraph 2 comes from transactions with the taxpayer or its associated enterprises.
Where, under the rules of a Member State, the tax base of a taxpayer is calculated according to point(a) of paragraph 2, the Member State may opt not to treat an entity orpermanent establishment as a controlled foreign company under paragraph 1 if one third or less of the income accruing to the entity or permanent establishment falls within the categories under point(a) of paragraph 2.
Where an entity or permanent establishment is treated as a controlled foreign company under paragraph 1, non-distributed income of the entity or permanent establishment shall be subject to tax to the extent that it is derived from the following categories.
As of the day following the promulgation of the amending law, the foreign permanent establishment of a residenttaxpayer shall not be considered a controlled foreign company in the business year in which each member of the shareholder has at least 25 per cent a shareholding, on the first day he has been listed for at least five years.
A foreign business site of a taxpayer withdomestic interests does not qualify as a controlled foreign company if on each day of a given business year, there was at least one member/shareholder with at least 25% share, which is a company or has an affiliate company that, on the first day of the business year, has been listed on a recognized stock exchange for more than 5 years.
However, Articles 43 EC and 48 EC are to be interpreted as not precluding national tax legislation which imposes certain compliance requirements where the resident company seeks exemption from taxes already paid on the profits of that controlled foreign company in the State in which it is resident,provided that the aim of those requirements is to verify that the controlled foreign company is actually established and that its economic activities are genuine without that entailing undue administrative constraints.
An entity orpermanent establishment shall not be treated as a controlled foreign company as referred to in paragraph 1 where not more than one third of the income accruing to the entity or permanent establishment falls within categories(a) to(f) of paragraph 2.
Hungarian regulations have already contained limiting ornegative rules for transactions concluded with controlled foreign companies(dividends received are taxable; stricter rules on the costs of transactions concluded with controlled foreign companies when assessing corporate tax bases).
Under United Kingdom tax legislation, the profits of a foreign company in which a UK residentcompany owns a holding of more than 50%(known as a controlled foreign company, or CFC) are attributed to the resident company and subjected to tax in the UK, where the corporation tax in the foreign country is less than three quarters of the rate applicable in the United Kingdom.
Articles 43 EC and 48 EC must be interpreted as precluding the inclusion, in the tax base of a resident company established in a Member State,of profits made by a controlled foreign company in another Member State, where those profits are subject in that State to a lower level of taxation than that applicable in the first State, unless such inclusion relates only to wholly artificial arrangements intended to escape the national tax normally payable.