United Kingdom

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

CFC Reform (PDF 747 KB)

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

 

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

Janette Wilkinson
Partner

+44 (0)20 7311 3254janette.willkinson@
kpmg.co.uk

Simon Palmer

Simon Palmer

Partner

+44 (0)20 7694 4411

simon.palmer@
kpmg.co.uk

 

Peter Scholes

 

Peter Scholes
Partner


+44 (0)20 7311 8343

peter.scholes@
kpmg.co.uk

 

Robin Walduck

 

Robin Walduck

Partner

 

+44 (0)20 7311 1816robin.walduck@
kpmg.co.uk

 

Michael Bird

 

Michael Bird

Director

+44 (0)20 7694 1717

michael.bird@
kpmg.co.uk

 

Kashif Javed

 

Kashif Javed

Director

+44 (0)20 7311 1441

kashif.javed@
kpmg.co.uk

 

Alastair Munro

 

Alastair Munro
Director

+44 (0)20 7311 4786

alastair.munro@
kpmg.co.uk

 

Robert Edwards

 

Robert Edwards

Senior Manager

+44 (0)20 7694 4709

robert.edwards@
kpmg.co.uk

 

Alison Hughes

 

Alison Hughes

Senior Manager

+44 (0)20 7896 4261

alison.hughes@
kpmg.co.uk

 

 

 

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