Detailed proposals for reform of the controlled foreign companies regime do not reflect the government’s ‘high level aims’, according to the Chartered Institute of Taxation.
The new CTA 2010 s 27 (attribution to persons of rights and powers of their associates) inserted by FA 2011 is reflected in an updated Small Profits Rate and Marginal Relief Toolkit, HMRC announced.
Inter-company debt: whether a ‘loan relationship’
The de minimis mismatch, how to identify the group and relevant companies, clearing intercompany loans ... Robert Langston looks at five key issues that arise in practice concerning the debt cap rules
Corporate loss carry-forwards are now as high as 25% of GDP in some countries, according to the OECD.
Ian Maston outlines how the IHT business property relief rules apply to groups of companies and similar structures
Robert Langston considers the practical issues and opportunities arising from the new branch exemption introduced by FA 2011 Sch 13