ARTICLE · 22 MARCH 2012

Controlled Foreign Companies Reform

Deloitte

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It has previously been announced that the Government will introduce a new controlled foreign company (CFC) regime in Finance Bill 2012. Draft legislation has already been circulated for consultation, most recently in February 2012.

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Deloitte Tax Group

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The measure

It has previously been announced that the Government will introduce a new controlled foreign company (CFC) regime in Finance Bill 2012. Draft legislation has already been circulated for consultation, most recently in February 2012.

The new CFC rules are intended to be more closely targeted at profits that are artificially diverted from the UK and a 'gateway' test has been developed which seeks to identify such profits. The February 2012 version of the draft legislation included refinements to the gateway test and in particular set out a number of scenarios where a CFC's business profits, other than financial and insurance profits, will be outside the scope of the CFC charge. These include:

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