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International briefing: September 2011

Your monthly review of key international tax issues by Chris Morgan, including comment on tax treaties anti-avoidance and the Anson case

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At the time of writing we are reaching the end of the consultation periods for this summer’s two most important international tax consultations: full CFC reform and the patent box proposals.

Unlike some years the summer period has not been completely free of new developments in the UK and I should like to highlight two of these: a new consultation on tax treaties anti-avoidance and the Upper Tribunal decision in the George Anson case better known as the Swift case.

Tax treaties anti-avoidance

On 1 August 2011 HMRC published a technical note setting...

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