Overview

Taxation of Foreign Profits 2012-2013 deals with the most extensive changes to UK law on taxation of foreign income in over 50 years. This new title provides timely and authoritative interpretation of the new 2009 rules addressing the taxation of Foreign Profits earned by UK companies and their subsidiaries and other significant changes affecting companies with cross-border investments. The 2012 edition includes a new chapter on CFC rules and how they affect the tax practitioner. A high profile and expert team of authors lead by General Editor Philip Baker QC with Consultant Editor Diane Hay explain the core issues stemming from the most extensive changes to UK law on the taxation of foreign income in over 50 years, and show how these rules will apply with examples of their practical application. Contents include coverage on: * Dividend Exemption * Worldwide Debt Cap (with dedicated sections on the impact for both the Banking and Insurance Industries) * Reporting of Worldwide Transactions * Controlled Foreign Company Rules * The Wider Context: the impact of Double Taxation Conventions (DTCs) and of EC Law * Branch profits exemption Unique to this title: * An accountant and lawyer author team write critical chapters to ensure 360 degree coverage of all elements through this expert partnership. * Chapters are structured to identify key issues in the interpretation and application of the new legislation, with a discussion of possible solutions. Each chapter contains practical examples of the impact of the new rules. The title benefits from the specialist knowledge of Consultant Editor Diane Hay and General Editor Philip Baker QC. Diane was previously a senior official of HM Revenue & Customs where she was a member of the HMT/HMRC Joint Steering Committee on Foreign Profits. Philip is one of the UK's most respected QCs and academics with a global reputation on international tax and treaty law. Their contribution allows practitioners to understand the background to this complex legislation and how the new rules fit into the global picture.

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