Katherine Blatchford and Simon Whitehead (Joseph Hage Aaronson) examine the European Commission’s preliminary decision.
The European Commission has published its preliminary decision that certain provisions of the UK’s controlled foreign company (CFC) rules (set out in the Taxation (International and Other Provisions) Act (TIOPA) 2010 Part 9A Chapter 9) constitute state aid. These reasons were set out in a decision letter addressed to the UK which was published in the Official Journal of the European Union on 24 November 2017.
The earlier excellent article in this journal (‘Can the UK CFC rules survive the EC’s state aid investigation?’ (David Harkness Dan Neidle & Rob Sharpe) Tax Journal 9 November 2017) regarding the Commission’s investigation preceded publication of the decision and commented on the press release the Commission had issued. That press release however was vague identifying the ‘group financing exemption’ in the CFC rules...
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Katherine Blatchford and Simon Whitehead (Joseph Hage Aaronson) examine the European Commission’s preliminary decision.
The European Commission has published its preliminary decision that certain provisions of the UK’s controlled foreign company (CFC) rules (set out in the Taxation (International and Other Provisions) Act (TIOPA) 2010 Part 9A Chapter 9) constitute state aid. These reasons were set out in a decision letter addressed to the UK which was published in the Official Journal of the European Union on 24 November 2017.
The earlier excellent article in this journal (‘Can the UK CFC rules survive the EC’s state aid investigation?’ (David Harkness Dan Neidle & Rob Sharpe) Tax Journal 9 November 2017) regarding the Commission’s investigation preceded publication of the decision and commented on the press release the Commission had issued. That press release however was vague identifying the ‘group financing exemption’ in the CFC rules...
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:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")