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Still Holding On To The Past?

Alastair Munro and Giuseppe Totino of KPMG's International and Finance Tax Group consider the current state of the UK's double tax relief (DTR) regime
This article will focus on some of the problems caused by offshore holding companies in particular the interaction of DTR with the controlled foreign company (CFC) rules and EU law and the likely future of the regime.
Introduction and background
It is now almost four years since the current DTR regime was introduced by the Finance Act 2000 (FA 2000). Taxpayers and practitioners alike continue to find many aspects of the rules unfathomable. Those perhaps hoping that the rules would soon be repealed under the pressure of lobbying before...

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