Market leading insight for tax experts
View online issue

Budget comment: on international taxation

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):...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.