UK and International Tax news
HMRC Issue Guidance On New CFC Regime
Wednesday 20th June 2012
Schedule 20 of the 2012 Finance Bill contains the draft legislation for the new Controlled Foreign Companies (CFCs) rules, and some amendments to the rules for the exemption of foreign permanent establishments that will apply to CFCs and permanent establishments with accounting periods that begin on or after 1 January 2013.
HMRC has recently published draft guidance on the Gateway – chapter 3, profits attributable to UK activities – chapter 4, non trading finance profits – chapter 5, and exemptions for profits from qualifying loan relationships – chapter 9.
Further guidance will be published over the summer and updated drafts of the chapter guidance documents will be issued when there are enough comments and examples to incorporate into an updated guidance chapter. The guidance will then be incorporated into HMRC’s International Manual in 2013.Contact Us