Anneli Collins and Tom Aston look at the possibilities of a branch profits exemption, how this might be structured and what it means for industry
Most people recognise that the introduction of the dividend exemption was a welcome step towards the UK adopting a more territorial approach to taxation. Indeed some asked why the UK didn't take a step further and also introduce an exemption for foreign branch profits. After all why shouldn't foreign branches and foreign subsidiaries be on the same footing? In response to this the Government announced in the 2009 Pre Budget Report that 'preliminary discussions' on a branch profit exemption would take place but emphasised that no policy decision had as yet been taken. This message was then reinforced and expanded at the recent ICAEW Annual Dinner when the Stephen Timms announce that 'a review of the taxation of foreign...
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Anneli Collins and Tom Aston look at the possibilities of a branch profits exemption, how this might be structured and what it means for industry
Most people recognise that the introduction of the dividend exemption was a welcome step towards the UK adopting a more territorial approach to taxation. Indeed some asked why the UK didn't take a step further and also introduce an exemption for foreign branch profits. After all why shouldn't foreign branches and foreign subsidiaries be on the same footing? In response to this the Government announced in the 2009 Pre Budget Report that 'preliminary discussions' on a branch profit exemption would take place but emphasised that no policy decision had as yet been taken. This message was then reinforced and expanded at the recent ICAEW Annual Dinner when the Stephen Timms announce that 'a review of the taxation of foreign...
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:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")