Jonathan Bridges and Michael Bird examine the types of arrangement that may not give rise to an artificial diversion of UK profits and hence not attract a CFC charge
In this article we offer our views on what the full CFC reform might mean for groups focused on holding their IP tax efficiently outside of the UK. We take a look at the types of arrangement that the government may accept as not giving rise to an artificial diversion of UK profits and hence not attracting a CFC charge. With the greatest risk of a CFC charge arising where IP is moved out of the UK an appropriate strategy going forward will likely be to adopt where possible a ‘day 1’ approach to IP planning – quite simply acquiring foreign IP into a tax-efficient holding location or creating and developing new IP in such a location. This...
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:
Jonathan Bridges and Michael Bird examine the types of arrangement that may not give rise to an artificial diversion of UK profits and hence not attract a CFC charge
In this article we offer our views on what the full CFC reform might mean for groups focused on holding their IP tax efficiently outside of the UK. We take a look at the types of arrangement that the government may accept as not giving rise to an artificial diversion of UK profits and hence not attracting a CFC charge. With the greatest risk of a CFC charge arising where IP is moved out of the UK an appropriate strategy going forward will likely be to adopt where possible a ‘day 1’ approach to IP planning – quite simply acquiring foreign IP into a tax-efficient holding location or creating and developing new IP in such a location. This...
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:
