Buy custom Taxation of foreign profits on companies

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It uses an all-or-nothing approach, where profits are either exempt or taxed in their entirety. According to the HMRC (2006) a company is defined as a CFC if it matches any of the following criteria:

? Resident outside the United Kingdom,

? Controlled by persons resident in the United Kingdom

? Subject to a level of taxation less than 75 per cent of the level that it would have paid had it been resident in the UK

The UK mostly targets portfolio income as it is easier to switch to tax havens often requiring only paper transactions...

Examples of these include interest, dividends and royalties (easy to sell patent to subsidiary in low tax country), otherwise known as mobile income. The reason for this is that if a company has gone to the trouble of purchasing a factory, assembling a workforce and establishing trade it is unlikely it has done so purely for tax avoidance reasons (Miller & Oats 2006)...

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