Sara Luder considers the proposed CFC regime for finance and IP companies, asking whether it will turn the tide on corporate migrations
Heather Self reviews the CFC reform proposals. Plus David Smith provides a view from business and Philip Baker QC considers whether the proposed rules comply with EU law
Your monthly review of key international tax issues by Chris Morgan, with comment on the patent box and CFC proposals and the informal consultation on the debt cap, and details of recent cases on EU issues
Detailed proposals for reform of the UK’s controlled foreign companies regime received a broad welcome from tax professionals but some experts warned that the new rules may not be compatible with European law.
Tax professionals have given a qualified welcome to detailed proposals for reform of the UK’s controlled foreign companies regime.
Bank loans to corporate borrowers are often supported by guarantees from related companies. Lydia Challen and Tim Harrop identify the principal tax issues on the provision of such a guarantee, from its creation to its termination
Cathryn Vanderspar and Charles Goddard examine how arguably outdated tax rules impact on the new financial landscape
Michael McKenna and Kunal Vyas review the impact of Bayfine UK and the OECD discussion draft on the meaning of ‘beneficial ownership’ on the interpretation of double tax treaties