Taxation of Foreign Portfolio Dividends

The greater part of the body of published professional comment to date on the proposals contained in the Treasury's discussion document on the Taxation of the foreign profits of companies has unsurprisingly been devoted to the proposed package of reform measures which concern the treatment of UK companies' participation holdings (that is to say broadly holdings of stakes of 10% or greater) in overseas companies. That package consisting of four substantial elements (exemption of dividends on participation holdings subject to various conditions a new 'controlled companies' regime to replace the UK's existing CFC code ...