½Û×ÓÊÓƵ

Controlled foreign companies (CFCs)

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Controlled foreign companies (CFCs)

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

The controlled foreign company (CFC) rules apply to companies that are not tax resident in the UK but which are controlled by UK residents. They also apply to foreign branches in respect of which an exemption election has been made. See the Foreign branch exemption ― overview guidance note for more details.

The CFC rules aim to prevent UK resident companies setting up subsidiaries abroad in order to divert and keep profits outside the UK tax net. Where an overseas company is a CFC, generally speaking, its chargeable profits will be attributed to its UK corporate shareholders so that they are charged to corporation tax on those attributed profits (the CFC charge).

The rules are complex and this guidance note outlines the main provisions only. More detailed commentary can be found in Simon’s Taxes D4.401.

HMRC guidance on the CFC regime is available at INTM190000 onwards.

CFCs ― basic principles

A CFC is any company which is resident outside the UK, but ‘controlled’ by a UK resident person or persons (which can be both companies and

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, and tax research, register for a free trial of Tolley+â„¢
Powered by

Popular Articles

Holdover relief for disposals by trustees

Holdover relief for disposals by trusteesOverviewWhere a capital gain has been realised on an asset that has been disposed of and that disposal was not for full value (that is not in an arm’s length sale) then holdover relief may be available. This will happen when trustees appoint capital assets

14 Jul 2020 11:54 | Produced by Tolley Read more Read more

Non-business expenses

Non-business expensesIntroductionIn order for an expense to be tax deductible it must be incurred because of an employee’s employment. Any non-business related expense is, therefore, not relievable except in some very particular circumstances.This guidance note deals with three separate issues. The

14 Jul 2020 12:16 | Produced by Tolley Read more Read more

Research and development (R&D) relief ― overview

Research and development (R&D) relief ― overviewThis guidance note provides an overview of the research and development (R&D) tax reliefs for companies.See the Research and development tax relief summary diagram which summarises the R&D tax relief.See also Simon’s Taxes D1.401.For a factsheet which

14 Jul 2020 12:22 | Produced by Tolley in association with Will Sweeney Read more Read more