Recent tax law changes have gone some way to justify the Government’s claim that the ‘UK is open for business’. But with many foreign jurisdictions still offering more competitive tax environments than the UK, Tim Brown investigates the feasibility of foreign profit attribution.
The coalition Government’s tax changes have included the well documented reduction in corporation tax to the baseline rate of 24%. Changes have also been made to the foreign profit rules so foreign subsidiary dividends, paid back to the UK, are tax exempt. Such amendments are unlikely to result in a frenzy of near-shoring of factories…
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