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

Winding up a trust ― legal, administrative and compliance issues

Winding up a trust ― legal, administrative and compliance issuesOverviewWhen winding up a trust, there are legal formalities and compliance issues that need to be dealt with, as well as IHT and CGT consequences that flow from the termination. This guidance note considers when and how a trust comes

14 Jul 2020 14:01 | Produced by Tolley Read more Read more

Entity classification

Entity classificationImplications of entity classificationIf a subsidiary is established, it is important to determine how it will be treated for UK tax purposes as this will determine the basis on which it is taxed. A subsidiary may either be transparent (like a partnership, where the individual

14 Jul 2020 11:37 | Produced by Tolley Read more Read more

Capital allowances on cars

Capital allowances on carsSummary of capital allowances on carsThe current capital allowance rates applicable to cars are as follows:Pool typeDescription of carRateLegislationMain rate poolNew and unused cars with CO2 emissions of 50g/km and below 18%CAA 2001, s 104AASecondhand cars with CO2

14 Jul 2020 11:08 | Produced by Tolley Read more Read more