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The other main reason of the reform is the uncertainty as to whether the UK's current regime is consistent with EU law, owing to the recent rulings of the European Court of Justice (ECJ) in current cases (Anon 2007).
Current UK Tax System
Currently, UK companies receiving dividends from other UK companies suffer no tax. Dividends from foreign companies on the other hand are currently subject to tax. The UK maintains a firm distinction between foreign direct investment (FDI) and portfolio investment. FDI (active) occurs when shareholdings greater than 10% are held, whilst, portfolio (passive) income is the term used when shareholdings are less than 10%...
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