KPMG United Kingdom

About
Transparency Report 2012

Our Transparency Report seeks to explain the steps that we take to uphold our professional obligations and responsibilities and how we ensure delivery of the highest quality in all of our services.

Our national charities

We are proud to be partnering with Action for Literacy and Shelter to enable us to play a greater part in tackling the key issues of literacy and homelessness in the UK today.
Industries
Insurance finance transformation

KPMG outlines how successful finance transformation programmes are structured focusing on reporting, process, people and technology to create a Target Operating Model that sets out management’s scale and ambition for change.

Tech Horizons

Emerging, evolving and expiring – our views on the technologies of today and tomorrow. Tech Horizons is an interactive tool, highlighting technologies or trends that will cause changes in the sector.
Services
- A-Z Services
Research
MF Global UK special administration

Richard Fleming, Richard Heis and Mike Pink of KPMG LLP have been appointed "Joint Special Administrators" of MF Global UK Limited. This website provides the latest updates and information from the Joint Special Administrators.

Fast Forward 2035

fast|forward is a new and exciting project by KPMG investigating the key corporate mega-trends that will change the future business landscape and the role of the CFO.
Careers
Live. Learn. Earn. The School and Colleges Leavers Programme

Explore your options in our e-zine, where you’ll find out more about whether our Audit, Risk Consulting or Gap Programme is for you.

Graduate Programmes

If you’re not a little bit scared, you’re not paying attention. Find out more about our graduate programmes in audit, tax, advisory and central services.
Media
KPMG in the UK on Twitter

Keep up to date with the latest news and views from KPMG in the UK by following our twitter feed.

KPMG blog

KPMG’s leadership blogs brings you insight, opinion and debate from our senior partners and industry experts.
Alumni
Connected 2012

Connected 2012 features interviews with many alumni including: Leslie Ferrar, Treasurer to The Prince of Wales; Joseph Wan, CEO of Harvey Nichols; Mark Donnelly, CFO of The Football Association; and Frank Bandura, CFO of Carluccio's Ltd.

LinkedIn

Over 11,000 of our alumni are registered on LinkedIn. We have established the KPMG UK Alumni group to enable you to contact many of our past and current people who are members.

Details

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

Controlled Foreign Company (CFC) Reform

The new Controlled Foreign Company (CFC) regime represents a fundamental change to the UK's corporate tax system aimed at enhancing the competitiveness of the UK as a holding location for multinational businesses. It is coming into force on January 1 2013 following a long and detailed period of consultation.

The new CFC regime affects overseas operations of companies based in the UK (both subsidiaries of inbound parents and British entities). The new rules are highly complex and present a number of compliance issues as well as some opportunities for reorganising business structures.

All affected companies will have to consider these new rules, weighing up the risks and also the opportunities present.

CFC Reform – an overview

The key points you need to know about the new regime can be found in our publication “CFC Reform”.

CFC Reform (PDF 747 KB)

Summary of new CFC rules

The new rules are more closely focused on the artificial diversion of profits from the UK, providing greater opportunity for activities, if properly structured, to be undertaken offshore without a CFC charge arising.

Controlled Foreign Companies - a summary of the new rules (PDF 680KB)

Finance Company Exemption under new UK CFC regime

New regulations enable companies based in the UK to make substantial tax savings on income from loans to foreign subsidiaries.

More information can be found in our publication: “Finance Company Regime”.

Or take a look at the video / read the one pager to find out more.

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

Information

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

Latest articles & publications

The new UK CFC regime – an M&A perspective (From Tax Adviser Magazine, October 2012)

Tax Policy Cycle

Back to Tax Policy Cycle

© 2013 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.

KPMG International Cooperative ("KPMG International") is a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.