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Staking the Territory

Alastair Munro, of KPMG, discusses the key aspects of the draft legislation published on 9 December 2008 for the proposed new exemption system for UK and foreign distributions

 
Alastair Munro of KPMG discusses the key aspects of the draft legislation published on 9 December 2008 for the proposed new exemption system for UK and foreign distributions
 
The publication of the draft legislation for the proposed new exemption system for UK and foreign distributions follows the Government's announcement in the Pre-Budget Report that it is proceeding with the introduction of the exemption as part of Finance Bill 2009. The new system represents a move towards a territorial basis of taxation in contrast with the current regime where foreign profits can be taxed either under the controlled foreign companies (CFC) rules (which continue to apply...

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