The ACT recognises the attempts made by HMT / HMRC to address the challenge of globalisation in tax matters. In particular there is a need to respond to changes in EU tax practice following judgements in the European Court of Justice (ECJ). The ACT supports the principle that the tax regime should be fair, double taxation should be avoided and that UK taxpayers should not be inherently disadvantaged in respect of other EU jurisdictions. The Foreign Profits consultation is potentially a very major change to the UK tax system however and there are a number of aspects to the discussion document which bear specific comment.