CFC reform and foreign branch taxation

SPEED READ In July, the Treasury published two documents taking forward the previous administration’s CFC reform and foreign branch exemption proposals, but more towards a welcome ‘Britain’s open for business’ approach. The consultation on CFC interim improvements has recently been extended to canvass views on raising the CFC de minimis exclusion level. The much longer foreign branch exemption discussion document covers several options, including retention of loss relief, and is open for comments until 15 October. Deutsche Shell, however, remains to be dealt with as forex relief on EU non-UK branch closures cannot be just optional. The next step is an open half-day briefing session on 7 September.