Where are we now? Michael Bird reviews the impact of latest developments
The proposals for the reform of the CFC rules published in January have been broadly welcomed. We are moving in the right direction but there is still much to be done before we have a workable set of rules which meet the stated objectives including making the rules more competitive; which is seen by many as critical for attracting businesses to and retaining them in the UK.
Chris Morgan and I wrote an earlier article in Tax Journal (Issue 1015 8 February 2010) which discusses the proposals. Based on these and comments made by HMT/HMRC since January I have considered below how changes to the CFC rules might influence how UK groups structure their operations going forward. Key to this would be the scope of redesigned exempt activities and motive tests.
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Where are we now? Michael Bird reviews the impact of latest developments
The proposals for the reform of the CFC rules published in January have been broadly welcomed. We are moving in the right direction but there is still much to be done before we have a workable set of rules which meet the stated objectives including making the rules more competitive; which is seen by many as critical for attracting businesses to and retaining them in the UK.
Chris Morgan and I wrote an earlier article in Tax Journal (Issue 1015 8 February 2010) which discusses the proposals. Based on these and comments made by HMT/HMRC since January I have considered below how changes to the CFC rules might influence how UK groups structure their operations going forward. Key to this would be the scope of redesigned exempt activities and motive tests.
...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
