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Case study: The CFC rules – help or hindrance?

Robert Gaut and Sarah Gabbai provide a case study setting out the tax issues for a US manufacturing group which migrates its non-US operations to the UK

Rightly or wrongly the current CFC regime has been held primarily responsible for the UK’s reputation as an unsuitable location in which to set up a holding company and do business.

It comes as no surprise therefore that the government’s consultation on a proposed new CFC regime is a particularly significant area of tax reform.

The following case study suggests that the UK’s reputation as a tax-unfriendly place to do...

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