The long-awaited draft UK controlled foreign companies (CFC) legislation was published in December 2011 with additional guidance and updated draft legislation issued on January 31 2012. The proposed rules affect transfer pricing by placing a new emphasis on significant people functions.
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Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.