Abstract

In the article the author atttt empts to answer the question on acceptability of using CFC regulations in the context of contracts on avoiding double taxation based on OECD Model Convention. Based on the current sounding of OECD Model Convention, guidelines included in Commentary on OECD Model Convention and foregoing practice of other countries, the author draws a conclusion on acceptability of using CFC regulations in Treaty relations. ThTh e key argument for such explanation is a subject-object separateness of taxation based on CFC regulations from regulated taxation regarding contracts on avoiding double taxation.