CFC proposals and general purpose exemption

Jeanette Zaman

Jeanette Zaman examines the structure of the new regime and the proposed general purpose exemption, which is intended to replace the current motive test

The eagerly awaited proposals for full reform of the CFC regime emerged on 30 June 2011 in the Consultation on Controlled Foreign Companies (CFC) Reform and the reaction to them over the coming months will be seen as a key measure of HMRC’s ability to listen and respond to the concerns of business.

Expectations have been high:

the Corporate Tax Reform paper published in November 2010 reiterated that Britain is ‘open for business’ and that the government is aiming to create the most competitive corporate tax regime in the G20; and
the interim measures in Finance Bill 2011 have generally been...

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Jeanette Zaman examines the structure of the new regime and the proposed general purpose exemption, which is intended to replace the current motive test

Expectations have been high:

the Corporate Tax Reform paper published in November 2010 reiterated that Britain is ‘open for business’ and that the government is aiming to create the most competitive corporate tax regime in the G20; and
the interim measures in Finance Bill 2011 have generally been...

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: