Tax and the City: February 2012 briefing

Helen Buchanan

In this month's briefing, Helen Lethaby reviews the latest CFC developments, the decision of the Indian Supreme Court in Vodafone, and a recent Tribunal decision concerning equipment leasing.

Controlled foreign companies

In response to feedback received on the draft provisions published in December HM Treasury and HMRC have published a new controlled foreign companies (CFC) policy document along with updated draft legislation insofar as it relates to finance profits and exempt foreign branches. Significantly:

The government has taken on board criticisms that the ‘gateway’ test is too complicated and is considering ways of redrafting the provisions so that groups can more readily ascertain whether or not particular companies are within the CFC regime.
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In this month's briefing, Helen Lethaby reviews the latest CFC developments, the decision of the Indian Supreme Court in Vodafone, and a recent Tribunal decision concerning equipment leasing.

Controlled foreign companies

The government has taken on board criticisms that the ‘gateway’ test is too complicated and is considering ways of redrafting the provisions so that groups can more readily ascertain whether or not particular companies are within the CFC regime.
...

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: