CFC reform - has the UK got it right?

  • Dec 2011
  • Newsletter/briefing

The UK is keen to adopt a more business and EU friendly controlled foreign company (CFC) regime, whilst retaining some protection against tax avoidance. Further details of the new CFC regime, which has been the subject of extensive consultation and is due to replace the existing CFC regime from the middle of next year, were published on 6 December 2011.

This briefing explains that there will be two alternative ways to fall outside the new CFC rules - the gateway test (which will exclude some or all of a CFC's profits), or a series of exemptions (which will be "all or nothing"). The structure of the regime is not that different from the existing regime, other than the crucial point that, under the new regime, only certain profits of the CFC will be apportioned back to the UK.


See also:

CFC reform: a Gateway update - Mar 2012

CFC focus - CFC reform and the EU - Mar 2012

CFC reform - further update - Feb 2012

 
 

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Sara Luder (partner)

 
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