Let's Talk Tax - June 2013

UK parented multinationals have a significant opportunity to save tax under CFC rules.

The new controlled foreign companies (CFC) rules provide UK parented multinationals with a significant opportunity to save tax. The finance company regime allows a UK headed group (or sub-group) to finance its overseas subsidiaries from an offshore finance company but pay UK tax at only one quarter of the main corporation tax rate (5.75% for 2013/14). In some cases, a full exemption is available, meaning no UK tax need be paid.

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