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Foreign branch exemption (CTA 2009 Pt 2 Ch 3A): acceptable tax competition/simplification or ‘the heist of the century’?

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Foreign branch exemption (CTA 2009 Pt 2 Ch 3A): acceptable tax competition/simplification or ‘the heist of the century’?


This dissertation considers the problems of double taxation and the different methods of providing relief from it, examining the issues in the context of tax competition and ambitions to simplify United Kingdom's tax regime. From 19th July 2011 it became possible for UK resident companies to elect for profits of their foreign permanent establishments to be excluded from the UK taxable base. The author assesses whether the changes introduced in the UK by s48 and Sch 13 Finance Act 2011 constitute acceptable tax competition and/or simplification and whether the change in tax law might be described as a "heist" - a metaphorical robbery involving the transfer of wealth from the poor and middle to the rich.

Adam, Timothy (2012) Foreign branch exemption (CTA 2009 Pt 2 Ch 3A): acceptable tax competition/simplification or ‘the heist of the century’? Masters thesis, Institute of Advanced Legal Studies, School of Advanced Study.


Item Type: Thesis (Masters)
Additional Information: Masters dissertation (distinction) - MA in Taxation (Law, Administration and Practice) (TAX)
Subjects: Law
Keywords: Tax competition, Taxation - Law and legislation - United Kingdom, Taxation - Law and legislation - European Union, International tax treaties, Double Taxation, Treaty Interpretation, OECD, Organisation for Economic Co-operation and Development, European Court of Justice
Divisions: Institute of Advanced Legal Studies
Collections: Theses and Dissertations > Dissertation
IALS Students
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URI: http://sas-space.sas.ac.uk/id/eprint/4721
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