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Budget analysis – International corporate taxation

Review of budget proposals by Chris Morgan and Alastair Munro

The Budget confirmed the Government's ongoing strategy on international corporate tax and brought few unexpected changes. However that is perhaps not surprising given the major changes to the tax system being wrought by the ongoing foreign profits reforms.

It was reassuring to see the Government confirm that the consultation on Controlled Foreign Companies (CFC) reform is running to timetable with more detailed proposals and draft legislation to be published later this year with a view to legislation being included in Finance Bill 2011. The Government will also bring forward its review of foreign branch taxation to run alongside the CFC reform with any legislative changes in Finance Bill 2011. Here the Government recognises the two sets of reforms are closely linked: a key purpose of any new CFC regime is to protect the UK tax base —...

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