TaxSource Total

Here you can access summary of the key current tax developments in Ireland, the UK and internationally as reported by Chartered Accountants Ireland

The report of key tax developments are displayed per year, per month, by Ireland, the UK or International and by report title

CFC Reform 2012

Last month HMRC published a number of updates and draft regulations in relation to the CFC legislation reform.

Further draft guidance on the new CFC rules is now available which includes draft guidance on Chapter 10 (exempt period exemption) and a short introduction to the new CFC rules, amongst others.

In addition draft regulations were also published for a banking safe-harbour and changes to the worldwide debt cap rules in Part 7 TIOPA.

The regulations proposed to change the worldwide debt cap rules are intended to ensure that the debt cap mechanisms for reducing or eliminating a corporation tax charge can also be applied, in appropriate circumstances, to a CFC charge. They do so by making sure that a CFC charge can be included as part of the allocated amount within the debt cap rules.