HMRC are seeking views on draft legislation, earmarked for Finance Bill 2012, to counter tax avoidance schemes exploiting double taxation agreements.
The objective of holding multinationals to account in relation to tax planning strategies – one of six stated ‘possible objectives’ – was discounted by a group of tax experts and practitioners reporting to the OECD in April on the case for greater disclosure of tax information.
The UK has become less attractive in recent years for firms that ‘rely more’ on capital allowances for plant and machinery and industrial buildings, according to research published by the Oxford University Centre for Business Taxation.
The Income Tax (Manufactured Overseas Dividends) (Amendment) Regulations, SI 2011/1787, amend SI 1993/2004 to take account of the reform of the taxation of foreign permanent establishments.
Bradley Phillips provides a one page overview of the CFC proposals set out in the 110 page consultation document
Helen Lethaby provides this month’s review of recent developments affecting the financial services industry
Jeanette Zaman examines the structure of the new regime and the proposed general purpose exemption, which is intended to replace the current motive test
Sara Luder considers the proposed CFC regime for finance and IP companies, asking whether it will turn the tide on corporate migrations
Stephen Fiamma and Stefka Kavaldjieva look at the increasingly global reach of FATCA and its impact here