We are expecting proposals on reforming the CFC rules and the taxation of foreign branches to be published imminently. Amendments to the Worldwide Debt Cap legislation and changes to consortium relief claims have appeared in the draft Finance Bill. HMRC has published new draft guidance on company residence. The ECJ has published its decisions in the Commission v Portugal case which looks at withholding tax on interest paid to non-resident financial institutions, and in the P Ferrero and General Beverage Europe joined cases that look at Italian adjustment surtax. The Australian Government has backed down regarding its proposals to bring in a 40% Resource Super Profits Tax.
