Government publishes
proposals to enhance UK attractiveness to multinationals
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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