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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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.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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