Policy paper
Controlled foreign companies: profit shifting
Controlled foreign companies: profit shifting
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This Tax Information and Impact Note switches off the partial exemption rules for loan relationship credits of a Controlled foreign companies that arise from an arrangement with a main purpose of transferring profits from existing intra-group lending out of the UK.
The measure also amends the anti-avoidance rule relating to the transfer of external debt to the UK to ensure that the rule works as intended.