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Full Of Eastern Promise … Not Quite!

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23 February 2003

Draft legislation was published recently which makes important changes to the 'exempt activities test' within the controlled foreign companies (CFC) rules. Chris Morgan and Michael Bird of KPMG's International Corporate Tax Group discuss the proposed changes and consider their impact

 
Draft legislation was published recently which makes important changes to the 'exempt activities test' within the controlled foreign companies (CFC) rules. Chris Morgan and Michael Bird of KPMG's International Corporate Tax Group discuss the proposed changes and consider their impact
 
The Inland Revenue announced as part of the Pre-Budget Report a number of changes to the exempt activities test. The first of the changes is to be welcomed as it makes it clear that companies in Hong Kong and Macao can potentially satisfy the test. However the other changes represent further anti-avoidance...

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