The Government today published a discussion document on proposals for reforming the UK tax treatment of controlled foreign companies (CFCs).
The proposals set out in the discussion document are intended to enhance the competitiveness of the UK, while providing adequate protection of the UK tax base. The discussion document sets out the overarching framework of the new rules and proposals for how monetary assets and intellectual property could be treated.
Financial Secretary to the Treasury Stephen Timms said:
"Modernising these rules is crucially important to maintaining and enhancing the UK’s attractiveness as a base for global business. This report, drawing on our discussions with businesses, is a key step in designing a system that better recognises the way multinationals operate today, while protecting our tax base."
The controlled foreign company rules exist to protect the UK corporation tax base and apply in situations where UK groups move profits into low tax jurisdictions to avoid UK tax. This reform forms the second part of the foreign profits package. The first part was introduced in Finance Act 2009 and included an exemption for foreign dividends and an interest restriction measure.
The full discussion document and other CFC reform publications are available at http://www.hm-treasury.gov.uk/controlled_foreign_companies.htm.
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