An updated ‘Gateway’ features in HM Treasury’s latest update on CFC reform, published yesterday.
James Wilson sets out a risk-based approach to the rules.
Mike Lane explains why the regime may be susceptible to challenge under EU law.
Martin Lambert and Zoe Wyatt provide a practical guide.
Michael Bird and Jonathan Bridges examine IP issues.
From Kevin Ashman, Tony Beare, Andrew Boucher, David Clissitt, Elizabeth Conway, Jonathan Cooklin, David Harkness, Robert Edwards, Aurell Taussig, Duncan Whitecross, James Wilson, Mark Edwards, Paul Morton and David Smith.
Paul Shaw and Kevin Cummings explain how to handle the tax rules on this topical issue.
Ashley Greenbank examines the draft provisions concerning distributions arising from intra-group transfers of assets.
HM Treasury has published an update and more draft legislation dealing with reform of the controlled foreign companies (CFC) rules. Two circumstances have been identified in which a full, rather than partial, finance company exemption will be offered.