Commentary

D4.402 Meaning of controlled foreign company

Corporate tax
Corporate tax | Commentary

D4.402 Meaning of controlled foreign company

Corporate tax | Commentary

Scope of CFC provisions

D4.402 Meaning of controlled foreign company

A 'controlled foreign company' is defined as a non-UK resident company (D4.403) that is controlled (D4.404) by a UK resident person(s)1.

'Control' is defined broadly for these purposes. Moreover, in certain circumstances a non-UK resident company that is not controlled by a UK resident person can still be a CFC (see D4.404).

Life assurance companies

The CFC rules require companies to look at each offshore fund individually each year and consider whether any chargeable profits fall to be charged to tax in the UK under the CFC rules. Life

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