After the excitement of the reform of foreign profits taxation in 2009 and the prospect of excitement to come in creating a CFC regime which is compatible with EU law it is not surprising that this year's first budget contained little of interest on the international tax front. Given the proximity of an election any contentious changes would be unlikely to survive the shredding of the first Finance Bill and might not appear in the second Finance Bill which will no doubt follow the election.
There are some relatively technical changes. The worldwide debt cap needs a number of changes to deal with issues that have arisen since last year (see Budget Note 6). Similarly the definition of 'relevant person' for the new remittance basis will be extended (BN 38). More wide-ranging changes are promised to counter avoidance using double taxation relief (see BN 17):...
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