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FOREIGN PROFITS


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.

Cathryn Vanderspar and Charles Goddard examine how arguably outdated tax rules impact on the new financial landscape

Ian Sandles examines the impact of the new rules on the financial sector

Tony Beare provides an overview of the measures in Schedule 13 of the current Finance Bill

TIEAs signed in January 2010 between the UK and the following territories entered into force on 19 May:

Responses to consultation sent a ‘strong message’ that applying the proposed tax exemption for overseas branch profits to all territories, and the inclusion of chargeable gains, would enhance the competitiveness of the UK regime, HM Treasury said.

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.

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