Foreign profits
Controlled foreign companies update: Treasury invites comments by 10 February
HM Treasury has published an update and more draft legislation dealing with reform of the controlled foreign companies (CFC) rules.…3 Feb 2012
2011 international review
A country-by-country guide to some of the key tax developments in 201115 Dec 2011
2011 review: international corporate taxes
Chris Morgan reviews the top five developments in 2011 affecting international corporate taxes15 Dec 2011
Offshore funds: practical problems
Eloise Walker looks at the practical problems thrown up by the new offshore funds rules8 Dec 2011
KPMG survey suggests progress on UK tax competitiveness
The UK’s corporate tax competitiveness ‘appears to have finally turned a corner’, KMPG said as it summarised the findings of…25 Nov 2011
Back to basics: Permanent establishments
Nick Farmer and Steve Hoare recap the rules in determining whether an overseas establishment is a PE, and the implications.18 Nov 2011
Roundtable discussion: tax competitiveness and CFC reform
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.11 Nov 2011
M&S: cross-border group relief
The Court of Appeal has handed down the latest judgment in the M&S group relief case. Alison Last assesses the impact of the decision.20 Oct 2011
Practice guide: handling commissionaire structures
Robert Langston outlines how commissionaire structures operate and the resulting tax risks following the Dell and Zimmer cases.20 Oct 2011
Tax and the City: October 2011 update
Helen Lethaby reviews the latest developments, including anti-avoidance concerning manufactured overseas dividends.20 Oct 2011
Case study: The CFC rules – help or hindrance?
Robert Gaut and Sarah Gabbai provide a case study setting out the tax issues for a US manufacturing group which migrates its non-US operations to the UK20 Oct 2011
Permanent establishment: OECD consultation
The OECD is inviting comments on proposed changes to the commentary on Article 5 of the OECD Model Tax Convention,…19 Oct 2011
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