Chris Morgan rounds up the latest developments in the international tax world
What’s hot? Corporate tax reform
As expected the Government published two documents at the end of July covering proposed international corporate tax changes: a short note on interim improvements to the controlled foreign companies (CFC) rules and a discussion document on the introduction of an exemption for foreign branch profits. In terms of the CFC proposals the note was short on detail and basically set out that the interim improvements will fall into three areas:
An exemption for ‘commercially justified’ activities which both business and HMRC agree do not erode the UK tax base but which could be caught under existing rules eg this might include a restructuring involving the transfer of a profitable non-UK business with third parties from one overseas territory to another.
Assistance for UK groups undertaking overseas acquisitions and re-organisations. For...
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Chris Morgan rounds up the latest developments in the international tax world
What’s hot? Corporate tax reform
As expected the Government published two documents at the end of July covering proposed international corporate tax changes: a short note on interim improvements to the controlled foreign companies (CFC) rules and a discussion document on the introduction of an exemption for foreign branch profits. In terms of the CFC proposals the note was short on detail and basically set out that the interim improvements will fall into three areas:
An exemption for ‘commercially justified’ activities which both business and HMRC agree do not erode the UK tax base but which could be caught under existing rules eg this might include a restructuring involving the transfer of a profitable non-UK business with third parties from one overseas territory to another.
Assistance for UK groups undertaking overseas acquisitions and re-organisations. For...
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:
