Ashley Greenbank examines the draft provisions concerning distributions arising from intra-group transfers of assets.
HM Treasury has published an update and more draft legislation dealing with reform of the controlled foreign companies (CFC) rules. Two circumstances have been identified in which a full, rather than partial, finance company exemption will be offered.
The UK’s proposed Patent Box legislation puts it on course to join a number of European territories that are favourably taxing certain intellectual property (IP) income.
Paul Morton reviews the top five tax developments in 2011 affecting in-house teams.
Multinational ‘tax dodges’ are estimated to account for over half of all illicit capital flight from developing countries, the European Network on Debt and Development (Eurodad), a network of NGOs from 19 European countries, has claimed.
Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.
Robert Langston answers a reader's question on the international transfer of property.