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Foreign profits
 
On 9 December HMRC released draft clauses for consultation (see http://www.hmrc.gov.uk/cnr/foreign-profits-draft.pdf) together with explanatory notes and draft guidance (see http://www.hmrc.gov.uk/cnr/tax-foreign-profits.pdf).
 
HMRC stresses that:
 
●     the clauses that ultimately appear in the Finance Bill are likely to differ from those published on 9 December and
 
●     the clauses may not meet their intended objective in some respects and this reflects the fact that they need to be developed further rather than any change of policy.
 
The Government says it would welcome comments on any aspects of the current draft of the debt cap measure that are thought to be in conflict with the stated policy intent.
 
Because the...

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