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 new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap