HM Treasury have released the slides from yesterday’s (February 23rd) stakeholder event - more detail to follow once I’ve got free of a 10 day case in court!
Posts Tagged: controlled foreign companies
26
Jan 10
UK: CFC discussion document published
HM Treasury has published the discussion document on the future of taxation of controlled foreign companies. Of particular interest to IP are the questions on how they should treat overseas companies with IP, proposing to distinguish between those that actively manage the IP and those that passively receive it. The effect would be to ensure that UK parent companies are not taxed on the profits of IP holding subsidiaries in certain circumstances (to be defined!)
The document simply asks questions at this point, rather than suggesting any particular line of thought. In particular, it seeks responses on what constitutes active management of IP – this is likely to be an interesting area of discussion, as many of the characteristics of active management would seem to reflect well-managed investment IP activities as well.
9
Dec 09
UK: Pre-Budget Report IP
The UK Pre-Budget Report today had a couple of IP moments – overall potentially useful, but really just not trying hard enough. It’s another missed opportunity, doing little or nothing to support the majority of IP-focussed business.
Continue reading →
11
Nov 09
UK: CFC reform slides published
The Treasury have published the slides from their stakeholder event (PDF) discussing the proposed reform of the controlled foreign companies rules in the UK.
13
Jul 09
EU: Fries with that?
McDonalds is relocating its European headquarters from an outlying part of London to Switzerland; needless to say, the move has absolutely nothing to do with tax. Of course not, it’s all about enabling McDs “to conduct the strategic management of key international intellectual-property rights, including the licensing of those rights to our franchisees in Europe, from Switzerland”.