Kevin Ashman

Tax Partner Hogan Lovells

Given that the consultations on reform started in 2007 it is unfortunate that fundamental issues still need to be resolved.

Consultations on reform of the CFC legislation have been going on since 2007. It is unfortunate that producing and refining the legislation has been squashed into such a short period in order to meet the government's commitment to include the provisions in Finance Bill 2012 so that it may come into force in respect of accounting periods beginning on or after 1 January 2013.

The draft legislation released in December and January is densely drafted and still requires significant...