UK and International Tax news

Revised Draft Regulations Issued On New CFC Regime

Monday 13th August 2012

Revised draft regulations have recently been issued in respect of the excluded territories exemption (ETE) by HMT.

The ETE is part of the CFC regime with its purpose being to exempt CFCs resident in territories where the CFC’s income is taxed at a rate broadly similar to that of the UK main corporate tax rate and where the CFC satisfies some general residence and income conditions.

The draft regulations provide the list of excluded territories and set out a simplified ETE that is available for CFCs in Australia, Canada, France, Germany, Japan and USA,  intended to allow groups to deal quickly with CFCs in these territories, which are major trading partners that have tax regimes broadly equivalent to the UK’s.

The simplified ETE is an additional, optional basis for exemption that will not affect entitlement to ETE under the normal rules.

Comments on the revised draft regulations should be made to HMRC by 28 September 2012.

Contact Us