Colin Hargreaves on the November 2010 CFC proposals
The government published various corporate tax reform proposals on 29 November. Comment here is confined to controlled foreign company (CFC) aspects of the proposals.
What’s proposed: longer‑term reforms
On CFCs a two stage process is still envisaged with interim improvements proposed for Finance Bill 2011 and longer‑term reforms in Finance Bill 2012. On the longer‑term reforms we have more detail on two particular aspects than on the wider regime. For the wider regime the proposal is for an entity based system which would impose a CFC charge only on profits which have been artificially diverted from the UK. There may yet be a whitelist-based exemption for specified jurisdictions which – if the scope is right – business would welcome.
Interest income: The first focus area is interest income. A ‘partial finance company exemption’ is...
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:
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
Home >Articles > Corporate tax reform: CFC proposals
Corporate tax reform: CFC proposals
Colin Hargreaves on the November 2010 CFC proposals
The government published various corporate tax reform proposals on 29 November. Comment here is confined to controlled foreign company (CFC) aspects of the proposals.
What’s proposed: longer‑term reforms
On CFCs a two stage process is still envisaged with interim improvements proposed for Finance Bill 2011 and longer‑term reforms in Finance Bill 2012. On the longer‑term reforms we have more detail on two particular aspects than on the wider regime. For the wider regime the proposal is for an entity based system which would impose a CFC charge only on profits which have been artificially diverted from the UK. There may yet be a whitelist-based exemption for specified jurisdictions which – if the scope is right – business would welcome.
Interest income: The first focus area is interest income. A ‘partial finance company exemption’ is...
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:
