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Details

Service: Tax, Corporate Tax, Tax Policy Cycle
Type: Business and industry issue
Date: 01/10/2012

Controlled Foreign Company (CFC) Reform: History of the policy development

The Government consulted extensively from June 2007 on proposals for a new Controlled Foreign Company (CFC) regime. Interim improvements were brought in with Finance Act 2011 whilst full reform of the CFC regime was included in Finance Act 2012. Below is a chronological record of the latter stages of this consultation from the publication of the Corporate Tax Reform Roadmap in 2010 through to the legislation published with the 2012 Finance Bill.

Next Steps
For most companies the new CFC regime in Finance Act 2012 will apply to accounting periods of CFCs beginning on or after 1 January 2013. HMRC’s draft guidance on these provisions is being published in stages over the summer before being incorporated into the International Manual in 2013.

Government amendments to Finance Bill tabled

On 24 May 2012 the Government tabled over 70 amendments to Schedule 20 of the Finance Bill which sets out the new CFC rules.

Read on to see details of the more important amendments (PDF 61.3 KB)

Finance Bill Published 29 March 2012

The Government has now published the Finance Bill which includes the latest draft of the new CFC rules, including a new temporary period exemption.

Read on to see a brief overview of the new rules and a summary of the latest key changes (PDF 68 KB)

Update document and revised draft legislation

On 29 February 2012 the Government published an update document and revised draft legislation including improvements to the operation of the gateway provisions and some amendments to the finance company exemption. Read on to see the key points from this latest announcement (PDF 64 KB).

Further draft legislation and update on the proposals

On 31 January 2012 draft legislation covering the application of the new CFC rules to exempt foreign branches and amended rules regarding the finance company partial exemption was published, together with an update on the latest thinking around the proposals. Read on to see the key points from this latest announcement (PDF 63 KB)

Finance Bill 2012 Draft Clauses – CFC Reform

CFC Reform Following publication of the draft legislation introducing a new CFC regime on 6 December 2011, KPMG in the UK has produced an in-depth analysis of the latest proposals. Read on to see KPMG’s analysis on the latest proposals (PDF 123 KB)

Access the draft legislation and supplementary paper (HM Treasury website)

KPMG’s CFC Reform Seminar with HMRC/HMT - Update

On 12 January 2012, KPMG hosted a seminar with HMRC/HMT to discuss the CFC Regime introduced in the draft clauses of the Finance Bill 2012. Read on to view the slides used during the session (PDF 721 KB)

CFC Interim Improvements - Finance Bill 2011 – 01 April 2011

A number of changes have been made to the CFC interim improvements included in Finance Bill 2011 to make it easier for businesses to benefit from them. Read on for KPMG’s view.

Corporate Tax Reform Roadmap - 29 November 2010

CFC reform was one of the five associated consultation documents dealt with by the Government on 29 November 2010 when an updated road map on corporate tax reform was published.Read on for KPMG’s view.

Contacts

	Janette Wilkinson Partner +44 (0)20 7311 3254janette.willkinson@ kpmg.co.uk		Simon Palmer Partner +44 (0)20 7694 4411 simon.palmer@ kpmg.co.uk
	Peter Scholes Partner +44 (0)20 7311 8343 peter.scholes@ kpmg.co.uk		Robin Walduck Partner +44 (0)20 7311 1816robin.walduck@ kpmg.co.uk
	Michael Bird Director +44 (0)20 7694 1717 michael.bird@ kpmg.co.uk		Kashif Javed Director +44 (0)20 7311 1441 kashif.javed@ kpmg.co.uk
	Alastair Munro Director +44 (0)20 7311 4786 alastair.munro@ kpmg.co.uk		Robert Edwards Senior Manager +44 (0)20 7694 4709 robert.edwards@ kpmg.co.uk
	Alison Hughes Senior Manager +44 (0)20 7896 4261 alison.hughes@ kpmg.co.uk

Latest articles & publications

Finance Company Exemption under new UK Controlled Foreign Companies regime

Tax Policy Cycle

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