The government’s roadmap for corporate tax reform was announced in the June budget with a proposal to reduce the tax rate to 24% by 2014 and a promise to look more widely at corporate tax to enhance the UK’s attractiveness to business. The stated aim is to develop the government’s view that ‘in general a broad tax base a low rate and a more territorial approach will improve competitiveness.’ As part of this the government is looking at the controlled foreign company (CFC) regime but the suggestion is that the roadmap could go wider and consider a range of possible options including possibly further rate reductions in return for more restrictions on tax reliefs. With further details due imminently the big question for business is around the precise details of these reforms: if the changes are to be tax neutral there must be...