Alastair Munro of KPMG discusses the key aspects of the draft legislation published on 9 December 2008 for the proposed new exemption system for UK and foreign distributions
The publication of the draft legislation for the proposed new exemption system for UK and foreign distributions follows the Government's announcement in the Pre-Budget Report that it is proceeding with the introduction of the exemption as part of Finance Bill 2009. The new system represents a move towards a territorial basis of taxation in contrast with the current regime where foreign profits can be taxed either under the controlled foreign companies (CFC) rules (which continue to apply in the medium term) or on repatriation with credit for foreign taxes.
This is one of the most significant changes to the UK tax...
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Alastair Munro of KPMG discusses the key aspects of the draft legislation published on 9 December 2008 for the proposed new exemption system for UK and foreign distributions
The publication of the draft legislation for the proposed new exemption system for UK and foreign distributions follows the Government's announcement in the Pre-Budget Report that it is proceeding with the introduction of the exemption as part of Finance Bill 2009. The new system represents a move towards a territorial basis of taxation in contrast with the current regime where foreign profits can be taxed either under the controlled foreign companies (CFC) rules (which continue to apply in the medium term) or on repatriation with credit for foreign taxes.
This is one of the most significant changes to the UK tax...
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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