Editorial

Christina Jackson

We all recall the government’s aim, set out in the Chancellor’s Budget speech in March, to create ‘the most competitive corporation tax regime in the G20’ through a series of corporation tax reforms – some inherited, some novel – which have since been the subject of much scrutiny from commentators, experts, competitors and pundits up and down the country. Six months on, and with a clearer idea of how these reforms will become manifest, we find ourselves at the tail end of the consultation period for controlled foreign companies (CFC) reform. Indeed, Parliamentary Counsel are well underway with the drafting of the specific legislation, due to be published at the end of the year. But do the proposals adequately balance the Government’s aim of preventing the artificial diversion of profits from the UK with the requirements of compliance with EU jurisprudence?