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CFCs
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CFCs
CFCS
International review for June 2022
Tim Sarson
Delay and a lack of political consensus on BEPS feature in this month’s review
by Tim Sarson (KPMG).
Tax and the City review for October 2021
Mike Lane
Zoe Andrews
The impact of the ruling in
Almacantar
, the latest on the economic crime levy and state aid issues are among the developments covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
State aid ruling on the UK’s CFC regime: an update on recovery
Paul Davison
Sam Withnall
Paul Davison and Sam Withnall (Freshfields Bruckhaus Deringer) report on the progress of the state aid recovery following the Commission’s final decision in its investigation last year.
Have changes to the UK’s CFC rules created thousands of ‘surprise’ CFCs?
Sophie Donnithorne-Tait
Serena Lee
Sophie Donnithorne-Tait and Serena Lee (Akin Gump) examine the rules using examples to illustrate outcomes pre and post January 2019.
2019 review: taxing times for corporates
Ashley Greenbank
Even without a Budget, 2019 has been a year of significant change to the taxation of corporates, writes Ashley Greenbank (Macfarlanes).
How to choose your holding company location
Sara Luder
Charles Osborne
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
UK SMEs expanding overseas through a local subsidiary
Daniel Sladen
Adam Kefford
What are the key tax issues for a UK SME establishing an overseas subsidiary? Adam Kefford and Daniel Sladen (PKF-Francis Clark) report.
The CFC group finance exemption: EC’s final decision
Francisco Alvarez Silva
Paul Farmer
Paul Farmer and Francisco Alvarez (Joseph Hage Aaronson) analyse the European Commission’s findings and the next steps to be taken.
EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
NEWS
Read all
UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
Read all
Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
MOST READ
Read all
Consultation tracker
When Ramsay does not rescue HMRC
Tax and the City for July 2026
BlueCrest: the impact for asset managers
HMRC v BlueCrest Capital Management (UK) LLP