Commentary

D4.411 CFCs: exempt period of exemption

Corporate tax
Corporate tax | Commentary

D4.411 CFCs: exempt period of exemption

Corporate tax | Commentary

D4.411 CFCs: exempt period of exemption

The purpose of the exempt period of exemption (EPE) is to provide a 'new' CFC with a grace period during which it can organise or reorganise its business so that a CFC charge does not arise, and to give the acquiring group's tax department sufficient time to complete their analysis of the new subsidiaries' affairs and make any necessary changes. In practice, the usefulness of this grace period is somewhat limited by the requirements of the rules.

The EPE operates by providing that for a period of 12 months a foreign subsidiary may be exempted

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