480. Imputation of chargeable profits and creditable tax of controlled foreign companies: overview.

The following provisions have effect in relation to accounting periods of CFCs beginning on or after 1 January 20131. A charge ('the CFC charge') is charged2 on UK resident companies3 which have certain interests in CFCs4. The CFC charge is charged by reference to the chargeable profits of CFCs5. A 'CFC' is a non-UK resident company which is controlled6 by a UK resident person or persons7. These rules are quite complex and the description that follows is a general overview of the key elements of the CFC regime.

The CFC charge is charged8 in relation to accounting periods9 of CFCs