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Foreign Profits

Peter Cussons, tax partner, PricewaterhouseCoopers LLP, provides an update and overview of the major developments in the foreign profits draft legislation since publication of the Finance Bill

 
Peter Cussons tax partner PricewaterhouseCoopers LLP provides an update and overview of the major developments in the foreign profits draft legislation since publication of the Finance Bill
 
To remind readers the Finance Bill foreign profits package comprised the distribution/dividend exemption the debt cap plus the abolition of controlled foreign company (CFC) acceptable distributions (ADP dividends). In addition the Finance Bill introduces prospective abolition of superior and international holding companies together with the International Capital Movements reporting requirements replacing Treasury consent after repeal. The fifth leg namely the introduction of a group version of CTA 2009 ...

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