Old CFC rules

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VAT—what is a transfer of a business as a going concern?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Cathya Djanogly 19th May
Practice notes
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May

Most recent Old CFC rules content

Q&As
Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449...
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23rd Jun
Practice notes
Old CFC rules—reductions in chargeable profits [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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5th Jun
Practice notes
Old CFC rules—interests and relevant interests [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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5th Jun
Practice notes
Old CFC rules—definition of a CFC: control [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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5th Jun
Practice notes
Old CFC rules—chargeable profits [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals with the old...
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5th Jun
Practice notes
Old CFC rules—exceptions from the CFC rules [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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5th Jun
Practice notes
A history of EU law and CFC regimes [Archived]ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note explains:•the...
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Produced in partnership with Kelly Stricklin-Coutinho 5th Jun
Practice notes
Old CFC rules—apportionment and tax charge [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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5th Jun
Practice notes
Old CFC rules—definition of a CFC: residence [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals...
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5th Jun
Practice notes
Old CFC rules—creditable tax [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note deals with the...
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5th Jun
Practice notes
Old CFC rules—definition of a CFC: company, accounting period and lower level of taxation [Archived]ARCHIVED: This Practice Note has been archived and...
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5th Jun

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