Controlled foreign companies (CFCs)

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Controlled foreign companies (CFCs)

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

The controlled foreign company (CFC) rules apply to companies that are not tax resident in the UK but which are controlled by UK residents. They also apply to foreign branches in respect of which an exemption election has been made. See the Foreign branch exemption ― overview guidance note for more details.

The CFC rules aim to prevent UK resident companies setting up subsidiaries abroad in order to divert and keep profits outside the UK tax net. Where an overseas company is a CFC, generally speaking its chargeable profits will be attributed to its UK corporate shareholders so that they are charged to corporation tax on those attributed profits (the CFC charge).

The rules are complex, and this guidance note outlines the main provisions only. More detailed commentary can be found in Simon’s Taxes D4.401.

HMRC guidance on the CFC regime is available at INTM190000 onwards.

CFCs ― basic principles

A CFC is any company which is resident outside the UK but is ‘controlled’ by a UK resident person or persons (which can be both companies

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+™
Powered by Tolley+

Popular Articles

Premiums on the grant or surrender of a lease

Premiums on the grant or surrender of a leasePremiums on the grant of a lease ― outlineWhen a property investor grants a lease, potentially this could be done on the basis that the tenant pays a premium for the initial grant of the lease, in addition to also paying rent over the term of the lease.

14 Jul 2020 12:58 | Produced by Tolley in association with Rob Durrant-Walker of Crane Dale Tax, part of AMS Group Read more Read more

Sales, advertising and marketing

Sales, advertising and marketingExpenditure on sales, advertising and marketing activities may include amounts which are disallowable for the purposes of calculating trading profits. This may be because the expenditure is:•capital in nature (see the Capital vs revenue expenditure guidance note)•not

14 Jul 2020 13:28 | Produced by Tolley Read more Read more

Holding companies ― VAT status of activities

Holding companies ― VAT status of activitiesThis guidance note examines how to determine the VAT status of a holding company’s activities. In particular, it looks at:•when a holding company is or is not in business•if a holding company is in business, whether its activities are exempt or taxableThe

14 Jul 2020 17:13 | Produced by Tolley Read more Read more