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PBR CFC Changes

Stephen Edge Slaughter and May brings us the City view on the Pre-Budget Report
The fact that the PBR contained detailed proposals (the new ICTA 1988 s 751A) designed to bring UK law into compliance with what was perceived to be the outcome of the Cadbury decision was a double surprise. First it was widely expected that HMRC would wait until the UK court had considered and commented on the Cadbury case — this approach risks further adjustment uncertainty once that happens. Secondly changes to the CFC rules were expected to be linked to any changes required to the taxation of foreign dividend income required by the FII litigation and at the time of the PBR the ECJ had not given its judgment in that case.

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