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Moving the Right Way?

Sara Luder of Slaughter and May gives her personal view on the draft provisions for the taxation of the foreign profits of companies
From a corporate tax perspective the UK is at a crucial point. Until about ten years ago the UK corporate tax regime made the UK a reasonably attractive location for holding company activities. The corporate tax rate was about average but the absence of a withholding tax on dividends and the strong treaty network both counted in the UK's favour. The same was true in relation to cross-border mergers. From a tax perspective at least and ignoring for a moment stamp duty the UK could make a good case that it should go 'on top'. Over the last few years however there have been two developments.

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