Taxation of Foreign Profits

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Taxation of Foreign Profits 2012–13 deals with the most extensive changes to UK law on taxation of foreign income in over 50 years.

A high profile team of authors, led by General Editor Philip Baker QC with Consultant Editor Diane Hay, explain the core issues stemming from the most significant changes to the taxation of foreign profits in the UK since the Second World War.

Contents include:
  • Introduction

  • Distribution Exemption

  • Branch Exemption

  • Debt Cap — General

  • Debt Cap — Insurance and Financial Services

  • Controlled Foreign Companies

  • EC Treaty Issues

  • Bilateral Treaty Issues

Unique to this title:

Expert explanation and comment on the reformed system, with practical examples and an emphasis on HMRC commentary and practice. Chapters are structured for ease of use and reference, with key issues highlighted and examples given of the operation of the provisions. This is up to date to include all the reforms completed in the Finance Act 2012, as well as subsequent HMRC commentary.

The title also benefits from the specialist knowledge of Consultant Editor Diane Hay and General Editor Philip Baker QC. Diane was previously a senior tax official of HMRC where she was a member of the HMT/HMRC Joint Steering Committee on Foreign Profits. Philip is a QC and academic with an established reputation on issues relating to international taxation and tax treaty law. They have worked with a high-level team of lawyers, accountants and former revenue officials in compiling this work.

As for 1st Edition


Richard Sumner  General editor
John Fairley  General editor
James MacLachlan  General editor
Ian Sandles  General editor
Neil Edwards  General editor
Alastair Munro, BA (Oxon), ATII  General editor
Patrick O'Gara  General editor
Philip Baker  General editor
Rupert Shiers  General editor
Peter Cussons  General editor
Diane Hay  General editor