
Taxation of foreign profits – changes to be made in Finance Bill 2009 |
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Taxation of foreign profits – draft legislation released
HM Revenue & Customs (HMRC) issued draft legislation of the foreign profits proposals on 9 December 2008. The drafts cover large parts of the legislative changes to be included in Finance Bill 2009, with some of it still in a fairly early stage of development. HMRC invites comments on the draft legislation by 3 March 2009.
The main points from the draft legislation include:
Actions to consider
The proposals raise significant issues and opportunities which need to be
considered now as they may require transactions to be implemented before the
commencement date. Groups need to consider the full impact of these changes,
potential solutions and opportunities and an appropriate course of action.
HMRC has invited comments on the draft legislation by 3 March 2009. This provides an opportunity for companies to contribute further to the discussion process and consider points on which further lobbying may be appropriate.
A more detailed overview of the draft legislation is available on PwCPlus.
In a webcast on 16 February, tax partner Peter Maybrey and colleagues analysed the draft legislation in the light of recent HM Treasury / HMRC open days, and considered what companies should be doing now. Watch the webcast on PwCPlus.
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PricewaterhouseCoopers international structuring tax specialists can help with any queries relating to how your business might be affected by changes to the rules for the taxation of foreign profits.
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