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UK: EC investigation, treatment of multinational groups under CFC regime

UK: EC investigation, treatment of multinational groups

The European Commission announced 26 October 2017, it was opening an in-depth investigation into the UK group financing exemption scheme that allows certain transactions by multinational groups to be exempt from the otherwise applicable rules on controlled foreign corporations (CFC) that target tax avoidance.


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As noted in an EC release, the EC believes that this special exemption may have given an unfair tax advantage to certain UK resident companies, in violation of EU state aid rules, and has decided to initiate a formal investigation procedure in order to validate its preliminary view. The EC will reach a final decision at the end of the formal investigation.


Read an October 2017 report [PDF 208 KB] prepared by KPMG’s EU Tax Centre

Read an October 2017 report prepared by the KPMG member firm in the UK

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