All posts with the topic: controlled foreign companies

The Autumn Statement 2012 contained a number of announcements of interest to individuals and small and medium-sized enterprises, but there was comparatively little of relevance to large companies and banks.    The main eye-catching announcement to affect corporates is the further 1% cut to the headline rate of corporation tax – the rate will reduce from 24% for the current year, to 23% from 1 April … Continue reading Corporation tax rate cut again, but pressure on corporate tax avoidance will only increase

The Budget did not signal any changes to the Transfer Pricing rules which is most welcome at this time as there is a packed schedule of initiatives over the next 12 months for transfer pricing at the OECD level, chief of which is the review and likely re-write of Chapter VI (Special Considerations for Intangible Property) and Chapter VIII … Continue reading Increasing reliance on Transfer Pricing principles?

As expected, the government has announced that a full reform of the controlled foreign companies (“CFC”) regime will be legislated for in Finance Bill 2012, with the new rules to take effect for accounting periods beginning on or after 1 January 2013.  The current CFC regime has been heavily criticised by business in recent years … Continue reading Controlled foreign companies

In the initial Coalition Agreement of 11 May 2010, the final Coalition Programme released on 20 May 2010 and the Queen’s Speech given on 25 May 2010 (as well as the recent speeches given by George Osborne) a number of initiatives and changes have been proposed by the Government in relation to the tax system, … Continue reading The Coalition Programme – Summary Of Taxation Proposals