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.
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 HMRC’s draft guidance on these provisions is being published in stages over the summer before being incorporated into the International Manual in 2013.