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CFC reform and foreign branch taxation

Peter Cussons reviews the current situation for taxation of controlled foreign companies and foreign branches

On the 27 July HM Treasury published two documents. First a short (three pages) note ‘Aim and Scope of CFC Interim Improvements’. Secondly ‘Foreign Branch Taxation: a discussion document’.

Both documents are the subject of consultation. In the case of the CFC interim improvements note discussions with business will take place this summer within working group meeting(s) at the end of July / beginning of August and further working group meeting(s) in August/September with a view to holding an open event now announced for 7 September.

In the case of the foreign branch taxation discussion document the consultation period runs from 22 July to 15 October.

In both cases it is anticipated that draft legislation will be published in time for inclusion in the Finance Bill...

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