Weekly tax highlights ― 16 December 2024

Produced by a Tolley Owner-Managed Businesses expert

Owner-Managed Businesses

Guidance

Direct taxes

Controlled Foreign Companies (Reversal of State Aid Recovery) Regulations, SI 2024/1307

These Regulations enable HMRC to repay tax and interest previously collected in response to a now overturned European Commission decision on the UK's CFC group financing exemption.

These Regulations enable HMRC to repay tax and interest that had been collected from MNEs in accordance with a European Commission decision on state aid (2019/1352). The Regulations aim to put taxpayer companies back in the position they would have been in had that Decision not had effect in the first place.

The state aid Decision related to the UK’s CFC group financing exemption. Amounts were collected under TIOPA 2010, Sch 7ZA, and that Schedule provides the mechanism for repayments in the event that the Commission Decision is overturned (which it was on 19 September 2024). The Regulations come into force on 31 December 2024, but adjustments can be made for amounts relating to any accounting period ending on or after 1 January 2019.

See Simon’s Taxes D4.431.

Joint sub-group scrutinises non-dom changes

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