Details

  • Service: Tax, Corporate Tax, Tax Policy Cycle
  • Type: Business and industry issue
  • Date: 16/08/2011

Controlled Foreign Company (CFC) Reform 

Since June 2007, the Government has been consulting extensively on proposals for a new Controlled Foreign Company (CFC) regime. The Government’s intention is to deliver a new regime which is competitive for business while providing adequate protection to the UK tax base. Interim improvements were brought in with Finance Act 2011 whilst full reform of the CFC regime is planned for Finance Act 2012.

 

Next Steps

The Finance Bill, which includes the latest draft of the new CFC rules, was published on 29 March 2012.  The Bill will now follow its normal passage through Parliament where it may be subject to amendment.  When the Bill receives Royal Assent it will become Finance Act 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.
 
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 ReformFollowing 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

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

Finance Bill 2011A 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

Corporate Tax Reform RoadmapCFC 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.

Contact

Simon-PalmerSimon Palmer

 

Partner

KPMG LLP (UK)
+44 20 7694 4411
simon.palmer@kpmg.co.uk

 

 

Michael-BirdMichael Bird


+44 20 76941717
michael.bird@kpmg.co.uk

 

Contact

Simon Palmer

Partner, KPMG LLP (UK)
+44 20 7694 4411
simon.palmer@kpmg.co.uk

 

Michael Bird
Director, KPMG LLP (UK)

+44 20 76941717
michael.bird@kpmg.co.uk

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