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Under Control?

Chris Morgan Alison Christian and Alastair Munro of KPMG's International Corporate Tax Group consider the Government's recently published discussion document on the taxation of foreign profits
On 21 June 2007 HM Treasury and HMRC published Taxation of the foreign profits of companies: a discussion document heralding what could be the most significant changes to the UK's corporate tax rules for decades. The document marks the beginning of a consultation process with business on four (and potentially five) key areas:
●     controlled companies (CCs);
●     foreign dividends including from portfolio investments;
●     deductibility of interest;
●     Treasury Consents; and
●     (possibly at a later date) foreign permanent establishments.
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