What counts as verified?
Official OECD Corporate Tax Statistics 2026 controlled foreign company rules dataset. Third-party list posts can help discover candidates, but they do not qualify as the final source for a retained row.
Controlled Foreign Company Rules by Country, 2026
Country-level controlled foreign company rule status, introduction year, activity requirements, and major exemptions across 146 jurisdictions.
357verified rowsJuly 29, 2026last checkedYearlyrefresh schedule
| # | Jurisdiction | ISO alpha-3 | OECD question | Rule code | Rule | Reported answer | Year | Official OECD source | Checked |
|---|---|---|---|---|---|---|---|---|---|
| 01 | Costa Rica | CRI | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 02 | Switzerland | CHE | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 03 | Angola | AGO | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 04 | Andorra | AND | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 05 | Anguilla | AIA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 06 | Antigua and Barbuda | ATG | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 07 | Armenia | ARM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 08 | Aruba | ABW | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 09 | Bahamas | BHS | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 10 | Bahrain | BHR | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 11 | Bailiwick of Guernsey | GGY | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 12 | Barbados | BRB | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 13 | Belize | BLZ | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 14 | Benin | BEN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 15 | Bermuda | BMU | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 16 | Bosnia and Herzegovina | BIH | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 17 | Botswana | BWA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 18 | British Virgin Islands | VGB | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 19 | Brunei Darussalam | BRN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 20 | Burkina Faso | BFA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 21 | Cabo Verde | CPV | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 22 | Cameroon | CMR | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 23 | Cayman Islands | CYM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 24 | Congo | COG | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 25 | Cook Islands | COK | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 26 | Côte dâIvoire | CIV | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 27 | Curaçao | CUW | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 28 | Democratic Republic of the Congo | COD | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 29 | Djibouti | DJI | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 30 | Dominica | DMA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 31 | Dominican Republic | DOM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 32 | Eswatini | SWZ | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 33 | Faroe Islands | FRO | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 34 | Fiji | FJI | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 35 | Gabon | GAB | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 36 | Georgia | GEO | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 37 | Grenada | GRD | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 38 | Guatemala | GTM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 39 | Haiti | HTI | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 40 | Honduras | HND | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 41 | Hong Kong (China) | HKG | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 42 | India | IND | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 43 | Isle of Man | IMN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 44 | Jamaica | JAM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 45 | Jersey | JEY | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 46 | Jordan | JOR | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 47 | Kenya | KEN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 48 | Kuwait | KWT | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 49 | Liberia | LBR | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 50 | Liechtenstein | LIE | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 51 | Macau (China) | MAC | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 52 | Malaysia | MYS | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 53 | Mauritania | MRT | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 54 | Moldova | MDA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 55 | Monaco | MCO | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 56 | Mongolia | MNG | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 57 | Montenegro | MNE | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 58 | Montserrat | MSR | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 59 | Morocco | MAR | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 60 | Namibia | NAM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 61 | Nigeria | NGA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 62 | North Macedonia | MKD | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 63 | Oman | OMN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 64 | Panama | PAN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 65 | Papua New Guinea | PNG | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 66 | Paraguay | PRY | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 67 | Philippines | PHL | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 68 | Qatar | QAT | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 69 | Saint Kitts and Nevis | KNA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 70 | Saint Lucia | LCA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 71 | Saint Vincent and the Grenadines | VCT | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 72 | Samoa | WSM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 73 | San Marino | SMR | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 74 | Saudi Arabia | SAU | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 75 | Senegal | SEN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 76 | Serbia | SRB | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 77 | Seychelles | SYC | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 78 | Sierra Leone | SLE | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 79 | Singapore | SGP | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 80 | Sri Lanka | LKA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 81 | Thailand | THA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 82 | Togo | TGO | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 83 | Trinidad and Tobago | TTO | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 84 | Tunisia | TUN | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 85 | Turks and Caicos Islands | TCA | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 86 | United Arab Emirates | ARE | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 87 | Uruguay | URY | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 88 | Viet Nam | VNM | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 89 | Zambia | ZMB | Is there a controlled foreign company rule in place? | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 90 | Israel | ISR | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 91 | Türkiye | TUR | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 92 | United States | USA | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 93 | Brazil | BRA | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 94 | Egypt | EGY | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 95 | Gibraltar | GIB | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 96 | Greenland | GRL | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 97 | Indonesia | IDN | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 98 | Kazakhstan | KAZ | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 99 | Maldives | MDV | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
| 100 | Malta | MLT | Substantial activity requirements | _Z | Not applicable | No | 2026 | Open source ↗ | 2026-07-29 |
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