- HM Revenue & Customs
- Part of:
- Autumn Statement 2013: HM Revenue and Customs for tax advisers, Corporation Tax, and Tax avoidance
- 5 December 2013
Controlled foreign companies: profit shifting
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.
Published: 5 December 2013