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United Kingdom - Controlled Foreign Companies Reform: How the Proposed New Rules Interact with Transfer Pricing Legislation

Country:
United Kingdom
Author:
D. Hay
Issue:
International Transfer Pricing Journal, 2010 (Volume 17), No 4
Published:
10 June 2010
On 26 January 2010 HM Treasury and HM Revenue & Customs (HMRC) issued their long-awaited discussion document setting out proposals for a reformed controlled foreign company (CFC) regime. This article examines some of the current ways these CFC and transfer pricing regimes interact, and the new potential interactions arising as a result of the CFC proposals.
 
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