Resumen de Tax holidays in a BEPS-Perspective

Hilde Bjerkestuen Mæhlum, Hans Georg Wille

• A tax holiday is a time-limited exemption from taxation and one of the most commonly employed tax incentives in developing countries.1 The main objective behind tax holidays is to attract foreign direct investment (FDI), as this is believed to stimulate economic growth and development.2 An exemption from taxation under a tax holiday could encourage investors to invest in developing countries.

  However, this requires the benefit under the tax holiday to actually accrue to the investor and not be consumed by taxation in the investor�s residence country. The subject of this article is the interrelation between tax holidays offered by developing countries and rules in industrialized countries for the taxation of income earned by controlled foreign companies (CFCs).