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Re: Brexit Development(s) Discussion
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Originally Posted by nomadking
Just more paperwork involved.
If I set up a company in France, then any profits are initially taxed to FRENCH rules. If I keep the money there and use the company to make investments in France, then it is nothing to do with UK authorities. If I then pay myself a "dividend", that would be subject to UK tax, taking into account the tax already paid in France.
NO TAX HAS BEEN AVOIDED.
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HMG seem to think differently...
https://www.gov.uk/government/public...ance-directive
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Two specific changes are being made to the UK CFC rules which will improve the protection they provide. These changes relate to the definition of control, and the treatment of certain profits generated by UK activity. These changes will make sure that the UK CFC rules comply with Council Directive (EU) 2016/1164, ATAD.
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This measure introduces 2 changes to the UK Controlled Foreign Company (CFC) regime.
The first change expands the scope of the control rules, which determine whether or not a non-UK resident entity falls within the UK CFC regime.
The second change restricts the scope of the full and partial exemption rules for finance profits, so that these exemptions are not available to the extent that key activities which generate such profits have been carried out in the UK.
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This measure is expected to impact on large multinational groups, with one or more UK tax resident companies, through introducing 2 changes to the UK CFC regime. One-off costs included familiarisation with these changes.
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