UK controlled foreign company (CFC) rules are going through a period of change. The government is trying to develop EC compliant legislation that achieves the twin objectives of minimising tax leakage through avoidance, while not being perceived as a barrier to business, so allowing the UK to remain commercially competitive, explains Ross Welland, tax partner at Haines Watts.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
The Brazilian law firm partner warns against going independent too early, considers the weight of political pressure, and tells ITR what makes tax cool
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default