CFC Consultation

HM Treasury has recently issued a consultation document that includes detailed proposals for how the new controlled foreign company (CFC) regime will operate. The proposed changes build on the interim improvements introduced in Finance Act 2011. The overall principle of the reform is that, where the CFC is held for genuine commercial reasons and does not pose a risk to the UK tax base, a number of exemptions will exist to remove the CFC from the regime. See Analysis, p 27