At the time of writing the 2011 Finance Bill (or as it is officially named: The Finance (No. 3) Bill 2010/11) has just been published and the detail missing from the Budget announcements is now available. There are a number of positive changes to the controlled foreign company (CFC) interim improvements and some points clarified in the Bill include:
A CFC will be treated as having a significant UK connection only if expenditure
in the UK exceeds 50% of its total expenditure and it is involved in a scheme which has a main purpose of achieving a reduction in UK tax;
IP will be treated as having a significant UK connection if it has been held in the UK in the preceding six years rather than ten years as was proposed before and the way in which the CFC is funded will no longer...
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At the time of writing the 2011 Finance Bill (or as it is officially named: The Finance (No. 3) Bill 2010/11) has just been published and the detail missing from the Budget announcements is now available. There are a number of positive changes to the controlled foreign company (CFC) interim improvements and some points clarified in the Bill include:
A CFC will be treated as having a significant UK connection only if expenditure
in the UK exceeds 50% of its total expenditure and it is involved in a scheme which has a main purpose of achieving a reduction in UK tax;
IP will be treated as having a significant UK connection if it has been held in the UK in the preceding six years rather than ten years as was proposed before and the way in which the CFC is funded will no longer...
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:
