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Foreign Profits: Tax Accounting

 
Mike McGowan Neil Henderson and Mark Couch of KPMG LLP consider the tax accounting implications under IFRS of the dividend exemption and debt cap rules introduced in Finance Act 2009
 
The taxation of foreign profits package introduced in Finance Act 2009 has been the subject of countless articles in this journal most of them focusing on the two most significant changes: the dividend exemption and the debt cap rules. There has been a lot of discussion on the cash tax implications of the new rules but there has been little focus so far on the tax accounting implications. This article aims to explain what if any are the effects of the dividend exemption and debt cap on the group tax charge of a multinational...

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