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Tax and the City: January 2012 briefing

Helen Lethaby provides your monthly update.

Quite a lot has happened since the last ‘Tax and the City’ article including publication of Graham Aaronson QC’s report on the merits of introducing a general anti-avoidance rule (GAAR) along with suggested drafting and publication of draft Finance Bill 2012 provisions.

Finance Bill 2012

Most of the draft provisions published on 6 December 2011 had been trailed already.

The structure of the draft controlled foreign companies (CFC) legislation is slightly different from that suggested by the June 2011 consultation document (the ConDoc) but the central precepts remain largely unchanged including a targeted effective tax rate by 2014 of 5.75% on profits from non-UK tax erosive intra-group...

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