An avoidance scheme in which the recipient of a manufactured overseas dividend (MOD) seeks a credit for UK income tax where ‘no actual UK income tax has been paid’ is to be blocked with effect from 15 September.
The Finance Act 2011, Section 43 (Appointed Day) Order, SI 2011/2280, appoints 15 September 2011 as the day on which FA 2011 s 43 comes into force.
Inter-company debt: whether a ‘loan relationship’
The UK and the US are acutely aware of the need for competitive effective tax rates but, as Steve Edge and Willard Taylor explain, they achieve that result in different ways.
With the SAO certification deadline looming for many companies, Ed Dwan explains how best to qualify or caveat the certificate where a particular area falls short of the requirements.
Control over corporation tax would provide the Scottish government with a significant new lever to help deliver its ambition to boost sustainable economic growth, according to a paper presented to the UK government last week.