UK and International Tax news

HMRC Issues Further Guidance On New CFC Regime

Thursday 4th October 2012

The 2012 Finance Act includes new rules for the reformed CFC regime which comes into effect for accounting periods beginning on or after 1 January 2013.

Following guidance issued earlier in June this year,  HMRC has now published further draft guidance on the following areas:

Chapter 6 – trading finance profits,

Chapter 8 – solo consolidation,

Chapter 11 – the excluded territories exemption,

Chapter 12 – the low profits exemption,

Chapter 13 – the low profit margin exemption,

Chapter 14 – the tax exemption,

Chapter 15 – relevant interests in a CFC,

Chapter 16 – creditable tax of a CFC,

Chapter 17 – apportionment of chargeable profits and creditable tax,

Chapter 18 – control,

Chapter 19 – calculation of the CFC’s profits and the CT assumptions used,

Chapter 22 – supplementary provisions.

Comments on the guidance have been requested by the end of October and the guidance will be incorporated into HMRC’s International Manual in 2013.

 If you would like further information on the new CFC rules, please contact Keith Rushen on +44 (0)20 7486 2378.

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