CFCs: proposals for full reform are unveiled

  • July 2011
  • Client publication/article

The proposals for full reform of the CFC regime reveal a complete overhaul and modernisation of the current exemptions. A question remains as to whether the Government will deliver a regime which is EU compliant given that the general purpose exemption, which is intended to be more flexible than the current motive test, still strays from the language used by the ECJ in Cadbury.

This article was originally produced for the 22 July 2011 edition of Tax Journal.

See also: Sara Luder's Tax Journal  article on the FinCo and IP aspects of CFC reform - Will the CFC changes turn the migration tide? - July 2011.

 
 

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