n Tax Breaks Newsletter - International tax and exchange control proposals : budget 2006

Volume 2006, Issue 242
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Extracted from text ... March 2006 7 BUDGET 2006 International tax and exchange control proposals By KATHY THERSBY KPMG's International Tax Mail sets out the most important of the Budget's international corporate tax and exchange control proposals: INTERNATIONAL TAX CONTROLLED FOREIGN COMPANY PROVISIONS The core philosophy of CFC taxation introduced in 1997 and developed since, will remain intact. The following issues have been identified as being anomalous and may be addressed in upcoming legislation: Treatment of certain CFC mobile businesses as qualifying business establishments. Treatment of royalties that are central to core active CFC business operations. Offshore business operations that ..

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