Rosemary Blundell National Tax Director of Mazars LLP explains why international groups should hold on to the transitional CFC exemption for holding companies
The current reform of the controlled foreign companies (CFC) rules in Finance Act 2009 precedes a longer-term overhaul of these provisions over the next two years. In the meantime we know that the acceptable distribution policy and non-local holding company exemptions in the exempt activities test are being abolished — with a two-year transitional period for the latter.
This article covers the abolition of the non-local holding company exemptions and why groups affected by this change should hold on to the exemption over the transitional period wherever possible.
Background
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Rosemary Blundell National Tax Director of Mazars LLP explains why international groups should hold on to the transitional CFC exemption for holding companies
The current reform of the controlled foreign companies (CFC) rules in Finance Act 2009 precedes a longer-term overhaul of these provisions over the next two years. In the meantime we know that the acceptable distribution policy and non-local holding company exemptions in the exempt activities test are being abolished — with a two-year transitional period for the latter.
This article covers the abolition of the non-local holding company exemptions and why groups affected by this change should hold on to the exemption over the transitional period wherever possible.
Background
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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