Sara Luder considers the proposed CFC regime for finance and IP companies, asking whether it will turn the tide on corporate migrations
The principal driver that pushed many UK multinationals to at least consider leaving the UK in the last few years has been the CFC regime.
In particular two areas of tax planning which were very difficult under the old CFC regime immediately became available to the migrating group: tax planning for intra-group financing and tax planning involving holding IP or brands or managing the business supply chain in a low taxed jurisdiction.
If the UK is truly ‘open for business’ and a competitive location for multinationals to be based the reform of the CFC...
