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News regs for controlled foreign companies

29 October 2012
Issue: 4377 / Categories: News , Companies
Move to allow application of debt cap mechanisms for corporation tax charge

Further regulations concerning controlled foreign companies (CFCs) have been published by the Treasury.

The first set ensure the debt cap mechanisms for reducing or eliminating a corporation tax charge can be applied, in appropriate circumstances, to a CFC charge by making sure the latter charge can be included as part of the allocated amount within the debt cap rules.

The second batch of new rules provide a capitalisation safe harbour in respect of banking CFCs within banking groups. If a banking CFC meets the conditions set out in the regulations, no charge will arise under the regime at TIOPA 2010, part 9A chapter 6.

Comments should be emailed by 21 November.

A final set of regulations concern the interaction of the new CFC regime with the rules for the taxation of offshore funds held by life insurance companies. They are designed to prevent double taxation and reduce compliance burdens in respect of life insurance companies’ offshore funds.

Remarks must be sent no later than 19 November.


Issue: 4377 / Categories: News , Companies
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