Jonathan Bridges and Michael Bird examine the types of arrangement that may not give rise to an artificial diversion of UK profits and hence not attract a CFC charge
Next week’s Finance Bill will include legislation to reduce the main rate of corporation tax to 26% from 1 April 2011 and 25% from 1 April 2012. The small profits rate will be reduced to 20%, as announced in the June 2010 Budget, from 1 April 2011.
The European Commission has proposed an optional ‘one-stop-shop’ system allowing companies to consolidate all profits and losses arising across the EU and file a single tax return.
Bill Dodwell on the Thin Cap GLO and the EU and national direct taxation
The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations, SI 2011/698, address a situation that is not covered by the current ‘disregard regulations’ (SI 2004/3256) which provide that certain foreign exchange gains and los
An ‘aggressive’ tax avoidance scheme putting ‘hundreds of millions of pounds’ of tax at risk was blocked with effect from 9 March in response to a disclosure made to HMRC under the scheme disclosure regulations.
Peter Cussons explains what the CCCTB proposals mean for UK and inbound groups
Chris Sanger on the cost of compliance and effective CT rates
Richard Bramwell QC on a purposive interpretation of distributions received by small companies