ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note deals with the old CFC rules that apply until the first accounting period of a CFC commencing on or after 1 January 2013. For a practice note on similar subjects under the new rules that apply from that date, see: CFC rules—definitions of company and accounting period and New CFC rules—entity level exemptions: not subject to a lower level of tax. A company is a controlled foreign company (a CFC) in an accounting period if it is: • resident outside the UK, which is further explained in Definition of a CFC—residence • controlled by persons resident in the UK, the residence of controllers is further explained in Definition of a CFC—residence and the meaning of control is explained further in Definition of a CFC—control, and • subject to a lower level of taxation in the territory in which it is resident, which is explained further below Meaning of Company in

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note deals with the old CFC rules that apply until the first accounting period of a CFC commencing on or after 1 January 2013. For a practice note on similar subjects under the new rules that apply from that date, see: CFC rules—definition of control. A company is a controlled foreign company (a CFC) in an accounting period if it is: • resident outside the UK, which is further explained in Definition of a CFC—residence • controlled by persons resident in the UK, which is explained further in this note, and • subject to a lower level of taxation in the territory in which it is resident, which is explained further in Lower level of taxation When assessing whether or not persons control a company, it is necessary to consider: • the specific CFC definition of control • the rules for joint control, and • the rules that attribute additional rights to a person in order to determine

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note deals with the old CFC rules that apply until the first accounting period of a CFC commencing on or after 1 January 2013. For a Practice Note on similar subjects under the new rules that apply from that date, see: CFC rules—determining residence of controllers and CFCs and New CFC rules—CFC's territory of residence. A company is a controlled foreign company (a CFC) in an accounting period if it is: • resident outside the UK, which is further explained in this note • controlled by persons resident in the UK, which is explained further in this note in relation to their residence and otherwise in: Definition of a CFC—control, and • subject to a lower level of taxation in the territory in which it is resident, which is explained further in: Lower level of taxation The concept of residence is used in a number of contexts in the CFC rules: • as set out above: ◦ the potential

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note deals with the old CFC rules that apply until the first accounting period of a CFC commencing on or after 1 January 2013. Once it has been established that a company is a controlled foreign company (a CFC) a CFC tax charge may still not arise where one of the exceptions applies. There are currently eight exceptions from the application of the CFC rules. They are exceptions for: • exempt activities • CFCs that are trading companies with a limited UK connection • CFCs that exploit intellectual property with a limited UK connection • chargeable profits under a de minimis threshold of £50,000 per 12 month period • relevant profits (calculated in a different way from chargeable profits) under a de minimis threshold of £200,000 per 12 month period • CFCs resident in an excluded territory • accounting periods that end within a period of grace, and • CFCs that pass the motive test Each

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note deals with the old controlled foreign company (CFC) rules that apply to accounting periods of CFCs starting before 1 January 2013. For a note on the same subject under the new rules see: CFC rules—interests and relevant interests As further explained in Old CFC rules—apportionment and tax charge, it is necessary to identify: • those persons who have an interest in the CFC, and • amongst those who have an interest, those who have a relevant interest in the CFC in order to be able to apportion the chargeable profits and creditable tax of the CFC and calculate any CFC tax charge due. This note explains the concepts of interest and relevant interests in a CFC in more detail. Who holds an interest in a CFC? A person (which includes any legal or natural person, eg both individuals and companies) is treated as holding an interest in a CFC if that person: • possesses or is entitled to acquire:

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note deals with the controlled foreign company (CFC) rules that apply for accounting periods of CFCs that start before 1 January 2013. There are four circumstances in which a UK resident company that holds a relevant interest in a CFC, and therefore would otherwise be apportioned an amount of the CFC's chargeable profits, can make an application to HMRC to reduce the chargeable profits, so that the amount apportioned and the corresponding CFC charge are reduced. These four circumstances are sometimes referred to as partial CFC exemptions. The four circumstances are where: • the CFC has a business establishment in the EEA • the CFC's profits include interest income the payer of which has been subject to a disallowance under the worldwide debt cap rules • full exception under the exceptions for trading or exploiting intellectual property (IP) with a limited UK connection are unavailable for certain reasons, and • the grace period for CFC treatment has been brought

ARCHIVED: This Checklist has been archived and is not maintained. This Checklist sets out historical provisions which were revoked on 1 April 2013 and is not maintained. However, due to transition arrangements, the provisions may continue to be relevant in proceedings where a conditional fee agreement or an insurance policy was entered into prior to 1 April 2013. These are the provisions referred to in CPR PD 48, para 1.3. Part CPR reference Provision (this is a copy of the CPR rule) Part 43Scope of costs rules and definitions 43.2(1)(a) costs includes fees, charges, disbursements, expenses, remuneration, reimbursement allowed to a litigant in person under rule 48.6, any additional liability incurred under a funding arrangement and any fee or reward charged by a lay representative for acting on behalf of a party in proceedings allocated to the small claims track 43.2(1)(k) funding arrangement means an arrangement where a person has—(i) entered into a conditional fee agreement or a collective conditional fee agreement which provides for a success fee

Law360, London: The ex-wife of a Russian oligarch lost on 18 March 2025 her application to have a split trial of her claim that Payne Hicks B-each LLP negligently failed to advise her to seize her ex-husband's US$200m super yacht in a divorce battle.

A state of limited competition whereby the market is characterised by a small number of producers or sellers.

Site of a new EPR reactor being built in Finland owned by Teollisuuden Voima Oyj (TVO). TVO operates two existing reactors at the site and, in addition to the EPR, a fourth reactor is to be built there although the timing for decisions on this has slipped.

1. What is the applicable legislation? The principal pieces of legislation governing the Omani foreign investment regime are Royal Decree No. 50 of 2019 promulgating the foreign capital investment law (Oman Foreign Capital Investment Law), Minister of Commerce, Industry and Investment Promotion Resolution No. 72 of 2020, issuing the Executive Regulations of the Foreign Capital Investment Law (as amended in 2022) (Executive Regulations) and Resolution No. 209 of 2020, Determining the List of Activities in which Foreign Investment is Prohibited (as amended in 2024). 2. Which government or other body (or bodies) reviews foreign investments? The Ministry of Commerce, Industry and Investment Promotion of Oman is the authority that approves the acquisition of shares and incorporation of Omani companies. If an acquisition involves a company in a regulated sector, approval of the relevant regulator may be required prior to the completion of the acquisition in order for the regulatory licence to continue unabated. 3. What is the scope of the foreign investment regime? Does it only apply to specific sectors or types of investors (eg

NOTE—to see whether notification thresholds in Oman and throughout the world are met, see further: Where to Notify. 1. Have there been any recent developments regarding the Omani merger control regime and are any updates/developments expected in the coming year? Are there any other ‘hot’ merger control issues in Oman? Competition, anti-monopoly and merger control in Oman is governed by Royal Decree No. 67 of 2014 promulgating the Competition, Protection and Monopoly Prevention Law (as amended) and its accompanying Executive Regulation issued by Ministerial Decision No. 18 of 2021 (together, the Competition Laws). The Competition Laws, Art 3 states that the law applies to all economic or commercial activities practiced in Oman and any economic or commercial activities practiced outside of Oman which has 'consequences prevailing in Oman'. The Competition Protection and Monopoly Prevention Centre (now absorbed into the Ministry of Commerce, Industry and Investment Promotion in Oman) (the CPMPC) is the regulatory body responsible for regulating