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FOREIGN PROFITS


Mike Lomax on the compliance implications of draft rules on foreign branch profits

A double taxation convention between the UK and Germany, signed in March 2010, entered into force on 30 December 2010 (see SI 2010/2975).

Baker Tilly observed that last year Cadbury paid UK corporation tax of around £197 million, and that the company has now announced plans to move its headquarters to Zurich ‘to take advantage of Switzerland’s more competitive tax regime’.

Peter Cussons on the foreign branch exemption

A competitive corporate tax system is not just about rates, the Treasury said as it launched five consultations.

The Treasury announced five consultations on 29 November dealing with controlled foreign companies, taxation of foreign profits, profits arising from patents and R&D tax credits:

Robert Langston provides a checklist of tax issues for companies considering debt funding into the UK

Chris Morgan provides a round-up of recent developments

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