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 you︀ do other work for it from Switzerland, it will still have to pay Swiss corporate︁ income tax. If this wasn’t the case, every single Swiss entrepreneur would just register their︂ company in the BVI and not pay Swiss corporate income taxes.
The same applies to︃ all other countries in theory. But some countries take a very, very relaxed approach to︄ these rules. So even if you live full time in a country, as long as︅ you only deal with foreigners for example, they may still consider your income “foreign-sourced” and︆ 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, it︈ would be considered a Swiss company if you manage it from Switzerland - even though︉ Switzerland does not have CFC rules.
When you look at CFC rules, you will also︊ often see that they only apply to passive investment companies, such as licensing companies.
