Michael Bird and Jonathan Bridges examine IP issues.
In March last year we wrote an article (‘IP planning post full CFC reform’ Tax Journal dated 25 March 2011) which considered how groups focused on holding IP tax efficiently outside the UK might be impacted by the CFC proposals contained in the Corporate Tax Reform document published in November 2010. At the time the proposals focused on using a ‘two-step’ approach to deal with IP.
Since then we have seen the government publish a further CFC consultation document and more recently issue draft legislation introducing the new...
