The proposals would affect a number of entirely bona fide commercial arrangements, argues Philip Baker QC. Kevin Cummings considers whether the proposals amount to an unecessary own goal. HMRC also give their response (below)
Robert Langston considers the practical issues and opportunities arising from the new branch exemption introduced by FA 2011 Sch 13
The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations, SI 2011/1787, amend SI 1993/2004 to take account of the reform of the taxation of foreign permanent establishments.
Bradley Phillips provides a one page overview of the CFC proposals set out in the 110 page consultation document
Jeanette Zaman examines the structure of the new regime and the proposed general purpose exemption, which is intended to replace the current motive test
Sara Luder considers the proposed CFC regime for finance and IP companies, asking whether it will turn the tide on corporate migrations
Detailed proposals for reform of the UK’s controlled foreign companies regime received a broad welcome from tax professionals but some experts warned that the new rules may not be compatible with European law.
Tax professionals have given a qualified welcome to detailed proposals for reform of the UK’s controlled foreign companies regime.