Equally the other Member States lack those protections as well. If we then come on to our cfc rules, we revamp our cfc rules broadly at the same time we much to a much more territorial system of tax. That slide gives a very broad summary of the old rules and the new rules. I think two key points about the old rules, they contained a quite strong presumption that activity should be in the uk if it could be, if you like. So therefore, there was a tendency for there to be a pull into the uk. If you moved activity from country x to country whyy, there might be a question why hadnt you moved it into the uk or where wasnt it in the uk in the first place. So that impact on foreign to foreign transactions was particularly crucial and prar particularly difficult for many businesses to handle. I think another key difference is the current rules are more proportionate proportionate. Under the old rules, you could in some circumstances have quite a lot of income that would have otherwise been caug
Broadly at the same time we much to a much more territorial system of tax. That slide gives a very broad summary of the old rules and the new rules. I think two key points about the old rules, they contained a quite strong presumption that activity should be in the uk if it could be, if you like. So therefore, there was a tendency for there to be a pull into the uk. If you moved activity from country x to country whyy, there might be a question why hadnt you moved it into the uk or where wasnt it in the uk in the first place. So that impact on foreign to foreign transactions was particularly crucial and prar particularly difficult for many businesses to handle. I think another key difference is the current rules are more proportionate proportionate. Under the old rules, you could in some circumstances have quite a lot of income that would have otherwise been caught by cfc rules and income that you would logically want to catch with cfc rules, you could avoid that be a technique called
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