Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.
The European Commission has published its final decision finding that the group financing exemption in TIOPA 2010 Part 9A Chapter 9 (‘Chapter 9’) involves unlawful state aid. The main change from its initial decision is that it now accepts that the exemption is justified as a proxy for the complex tracing exercise required by the UK capital criterion in TIOPA 2010 Part 9A Chapter 5 (‘Chapter 5’). It remains of the view however that the exemption from the application of the ‘significant people functions’ (SPF) criterion in Chapter 5 is unlawful.
Does the group financing exemption provide an advantage?
The Commission concluded that the exemption allowed UK companies with a controlled foreign company (CFC) earning non-trading finance profits (NTFP) from loans made to...
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Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.
The European Commission has published its final decision finding that the group financing exemption in TIOPA 2010 Part 9A Chapter 9 (‘Chapter 9’) involves unlawful state aid. The main change from its initial decision is that it now accepts that the exemption is justified as a proxy for the complex tracing exercise required by the UK capital criterion in TIOPA 2010 Part 9A Chapter 5 (‘Chapter 5’). It remains of the view however that the exemption from the application of the ‘significant people functions’ (SPF) criterion in Chapter 5 is unlawful.
Does the group financing exemption provide an advantage?
The Commission concluded that the exemption allowed UK companies with a controlled foreign company (CFC) earning non-trading finance profits (NTFP) from loans made to...
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:
