While there are various unilateral anti-avoidance measures like thin capitalization
rules and anti-treaty shopping provisions (for a brief overview
see Arnold and McIntyre, 1995: 69–88), a particularly prominent case is
the introduction of CFC legislation. In the 1960s the US, under President
Kennedy, was the first country to introduce such legislation. CFC rules
are aimed at the use of foreign subsidiaries as base or conduit companies
in tax haven countries, which serve no substantive economic purpose
but the tax-privileged holding of assets for the group. Resident
shareholders controlling a subsidiary in a tax haven are taxable on the
income of that subsidiary in the current period, whether or not the income
is actually distributed to them. Thus, CFC rules pierce the ‘corporate
veil’ of the tax haven entity and violate the principle of separate entity
accounting.