2011 saw the introduction of many of the practical aspects of the debt cap regime. Interim improvements to the CFC regime were included in Finance Act 2011 and took effect for periods beginning on or after 1 January 2011. An optional exemption from corporation tax for profits made by overseas branches was introduced in Finance Act 2011 to take effect from Royal Assent. 2011 was the year that much of the world began to take notice of FATCA and began to focus on implementation in 2012. Over the course of 2011 activity by pension funds around submitting EU claims for recovery of withholding tax has really taken off.
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