2010 has been a busy year in the area of international corporate tax. The debt cap rules took effect from 1 January 2010. Although we have had no legislative change there has been a lot of activity in the ongoing reform of the UK CFC rules and proposals for branch exemption and an IP Box. Changes to the rules on claiming back tax paid under mistake of law have affected the ability of taxpayers to make EU claims. We have had significant uncertainty around the tax treatment of capital distributions. The Swift case created an uncertainty for UK groups with operations in the US structured through LLCs.
