Implementation of the ATAD Rules on Controlled Foreign Companies: A Nordic Member State Perspective

Peter Koerver Schmidt, David Kleist, Juha Lindgren

Research output: Contribution to journalJournal articleResearch


This article analyses the implementation of the controlled foreign company (CFC) rules in the ATAD in the Nordic Member States. In addition to comparing the amended CFC regimes of Sweden, Finland and Denmark, the authors discuss their relationship with EU primary law and the expected impact of the OECD’s work on Pillar Two. Although material differences between the CFC regimes still exist, the authors find the ATAD to be a step in the right direction.
Original languageEnglish
JournalEuropean Taxation
Issue number10
Pages (from-to)425-439
Number of pages15
Publication statusPublished - Oct 2021

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