TaxCorporate TaxAdvisers await foreign profits plans in PBR

Advisers await foreign profits plans in PBR

Tax advisers hopeful to see a change of plans on foreign profits in next Monday's pre-Budget report

Bill Dodwell, tax partner at Deloitte

Bill Dodwell, tax partner at Deloitte

Tax advisers will be scrutinising Monday’s pre-Budget report for evidence
that the government has had a change of heart on its foreign profits plans.

The moves, which will tighten up the taxation of offshore subsidiaries –
which the Treasury believes are for tax avoidance – have alienated companies,
some of which have announced plans to leave the UK.

Bill Dodwell,
Deloitte
tax partner, said business needs clarification from the Treasury on the
direction of the
Controlled
Foreign Companies
(CFC) laws.

‘Unless they relax laws in the future then they’re going to see companies
emigrate. Are we going to see some improvements from the PBR? No-one is leaving
because they don’t have a dividend exemption,’ he said.

The ‘Treasury Consent’ regime is likely to be abolished, advisers also
believe.

Many argue the concept of the regime has been effectively redundant for some
20 years. Currently, if UK-based companies issue shares or debt overseas, they
must seek government permission.

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