Avoiding the new CFC rules - USERNAME: Warling - 30/01/2014
Tax Question: Our non-resident UK offshore subsidiary is expecting profits over the ?500k de-minimis limit, so we are exploring scenarios where the CFC rules won´t apply and so no additional UK corporation tax is due. 1 - What if the offshore subsidiary had profits of more than ?500k but also is located in Malta, which has a headline corporation tax rate of 35%. But 5% ater refunds via the imputation system]. Is it then exempt from CFC rules on the basis it pays "no less than 75% o the UK equivalent". ? 2 - In a structure of UK parent > ... (to read the remainder of this article, please log in below.)
Tax Question: Our non-resident UK offshore subsidiary is expecting profits over the ?500k de-minimis limit, so we are exploring scenarios where the CFC rules won´t apply and so no additional UK corporation tax is due. 1 - What if the offshore subsidiary had profits of more than ?500k but also is located in Malta, which has a headline corporation tax rate of 35%. But 5% ater refunds via the imputation system]. Is it then exempt from CFC rules on the basis it pays "no less than 75% o the UK equivalent". ? 2 - In a structure of UK parent > ... (to read the remainder of this article, please log in below.)
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