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Taxation of Foreign Profits

Jo Myers and Ken Almand both Senior Consultants on Ernst &Young's International Tax Services team review the proposals for restricting interest deductions in the Foreign Profits of Companies discussion document
HMRC proposals regarding interest deductions
The discussion document The Taxation of the Foreign Profits of Companies was published by HMRC on 21 June 2007. This document sets out a package of proposals for discussion with business and business advisers with the aim of developing more detailed proposals for further discussion. At this stage none of the proposed changes will necessarily become law. There is therefore an opportunity to consider whether the proposed changes (or indeed any others) are needed to the UK's current legislation governing the deductibility...

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