JustAnotherNomad said:
I literally explained to you the difference between CFC rules and permanent establishment/corporate tax residency.
CFC rules are some sort of “catch all” rule, “if none of our other rules apply to you, then at least we will get you with this one.”
CFC rules are about corporate ownership, not about where the company is managed, since that's already covered by other rules.
I always pick Switzerland as an example because it should be so obvious: Switzerland doesn't have CFC rules, but if you manage your offshore company from Switzerland or if you do other work for it from Switzerland, it will still have to pay Swiss corporate income tax. If this wasn't the case, every single Swiss entrepreneur would just register their company in the BVI and not pay Swiss corporate income taxes.
The same applies to all other countries in theory. But some countries take a very, very relaxed approach to these rules. So even if you live full time in a country, as long as you only deal with foreigners for example, they may still consider your income “foreign-sourced” and not subject to tax. But this really depends on the country. In the above example, even if you had a BVI company that only sold to customers outside Switzerland, it would be considered a Swiss company if you manage it from Switzerland - even though Switzerland does not have CFC rules.
When you look at CFC rules, you will also often see that they only apply to passive investment companies, such as licensing companies.
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