CFC rules—definitions of company and accounting period

Copyright © 2025 LexisNexis
Published by a LexisNexis Tax expert
Practice notes

CFC rules—definitions of company and accounting period

Copyright © 2025 LexisNexis

Published by a LexisNexis Tax expert

Practice notes

This Practice Note deals with the new controlled foreign company (CFC) Rules that apply for accounting periods of CFCs commencing on or after 1 January 2013. For a Practice Note on similar subjects under the rules that applied until then, see: Old CFC rules—definition of a CFC: company, accounting period and lower level of taxation.

The definition of company determines what entities can be CFCs and the definition of an accounting period determines the period over which a CFC charge can arise and other measures are tested. As a result they are important concepts to understand.

Meaning of company in the CFC context

Other than in respect of cell companies, as explained below, 'company' in a CFC context has the broad Corporation Tax Acts meaning of any body corporate or unincorporated association (which is discussed in more detail in: Who is liable to pay corporation tax?).

The term ‘body corporate’ is not defined in UK tax legislation and takes its ordinary meaning. Significant indicators or characteristics of a body corporate are that it has:

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Rules definition
What does Rules mean?

The detailed provisions of a pension scheme.

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