The recent UK Budget included changes to the CFC rules and an unexpected decrease in the corporation tax rate which could impact the overseas CFC analysis for some inbound groups. The recent Anson case creates uncertainty for groups with US LLCs in their structures; and the BT Pension Scheme case is continuing its way through the courts. There are further updates on ongoing reform in Switzerland and Greece; and new proposals affecting the tax treatment of dividend payments announced in Austria and the tax consolidation regime in Luxembourg.
