International Tax Blog
New CFC Rules (Part Two)
This is the second blog in a two part arrangement covering the proposed changes to the UK CFC rules. As explained last time around the issue of CFC legislation for SMEs has been largely dealt with by HM Treasury (HMT) by the introduction of a £500k de-minimus profit limit – that means that most SMEs will fall outside the CFC regime.
Read moreNew CFC Rules
Between 2007 and 2011 a number of UK Plc’s departed these shores. Brit Insurance, Shire and WPP all ‘left’ the UK tax net. Their beef was with the UK’s controlled foreign company (CFC) regime that was perceived as draconian and uncompetitive when compared with other foreign tax regimes.
Read moreImage Rights Companies
On 6th December 2011 HM Treasury announced that for the second time in three years they would grant a tax exemption to non UK resident footballers playing in the UEFA Champions League Final. This includes remuneration paid by their clubs and amounts due to them under sponsorship and endorsement agreements.
Read moreA Day of Change – 6 December 2011
We always knew that Tuesday 6 December 2011 would see quite a lot of interesting UK tax code developments where international issues were concerned – however, it’s not until I’ve actually sat down and skim read through all of the press releases, and absorbed the tweets and early stage reviews of many other peers that it becomes clear just how much has been included today that is going to keep me busy! The business case I need to put together to secure the recruitment of an assistant has basically been written for me......
Read moreM&S Group Relief Case
Apart from very much enjoying the high quality produce offered by the local M&S foodhall in Longwell Green, the British retail giant M&S has also provided me with a lot of tax related reading over the last ten years.
Read moreThe Tax Information Exchange Agreement
In years gone by many offshore tax structures relied upon the fact that a person’s local tax authority didn’t know that they held cash or other income producing assets in an offshore jurisdiction. The income was not disclosed upon a domestic tax return and life went on – the local tax authority was none the wiser.
Read moreForeign Branches
For those of you who know your international tax matters well (or those who have followed my blog), from 1 July 2009 dividends received by UK resident corporate from overseas companies are generally exempt from UK taxation. This was a major change to the UK tax system because it sees the beginning of a move to a territorial system of taxation (i.e. value is taxed where it is created, not where the taxable person is resident).
Read moreThe Vestey Brothers
As I looked through the Times Top Track 250 for 2011 I noticed a business called The Vestey Group.Precisely one hundred years ago in 1911, the Vestey family pioneered the use of refrigerated ships to transport egg products from China to the bakery trade in Britain, America and continental Europe. Today its main business, with operations in 17 countries, supplies seafood, dairy products and meat to the retail, hotel, restaurant and wholesale sectors. The group also owns cattle farms in South America and a luxury-food distribution business.
Read moreTreaty Abuse: The HM Treasury.
On 1 August 2011 HM Treasury quietly published a document setting out their plans to add an additional layer of anti avoidance provisions in respect of ‘treaty shopping’.
One of my previous senior colleagues often used the phrase ‘treaty shopping’ with me on projects and initially I needed to look up what he was banging on about. It turns out that it was nothing more than creating a tax efficient bridge between two jurisdictions.
Read moreInternational Tax Matters for SMEs
Last time out I mentioned withholding taxes. If you are doing business abroad it’s crucial you understand what these are and broadly how the system works.
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