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Taxation of foreign profits

The Government has today announced that it will issue a consultation document later in the spring, which will concentrate on the taxation of foreign dividends received by UK companies and the rules on Controlled Foreign Companies (CFCs). The Government has said it will consider a number of options, including exempting foreign dividends and introducing income-based CFC rules. In addition, the document will consider the impact of any reform on other aspects of the UK tax regime, such as any potential limitation on interest relief. The announcement follows a Government consultation with business on the taxation of foreign profits and the competitiveness of the UK.
 

Our view
We welcome the proposed consultation document, particularly in light of the rather unsatisfactory proposed CFC legislation issued at the time of the Pre Budget Report in December 2006, in response to the ECJ’s decision in the Cadbury Schweppes case. However, business will not welcome the introduction of any further restrictions on the deductibility of interest.