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Full Of Eastern Promise … Not Quite!

 
Draft legislation was published recently which makes important changes to the 'exempt activities test' within the controlled foreign companies (CFC) rules. Chris Morgan and Michael Bird of KPMG's International Corporate Tax Group discuss the proposed changes and consider their impact
 
The Inland Revenue announced as part of the Pre-Budget Report a number of changes to the exempt activities test. The first of the changes is to be welcomed as it makes it clear that companies in Hong Kong and Macao can potentially satisfy the test. However the other changes represent further anti-avoidance measures. The Revenue has said that these are intended to ensure that profits from extended warranties and similar products are taxable under the CFC rules. However from a reading of the draft legislation (which is to be included in...
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