Controlled Foreign Company (CFC) interim improvements

May: Clause 47 and Schedule 12 of the Finance Bill contain interim improvements to the existing CFC rules and were presented to Parliament in The Finance (No 3) Bill on 29 March 2011.

The legislation for the CFC interim improvements is available on the parliament website and as well as draft guidance from HMRC (PDF, opens in a new window).

HM Treasury and HMRC invite comments on the draft guidance with a view to ensuring that it is as helpful as possible to users.

Please provide any comments by 15 September 2011 to:

• Mark Bryan (HMRC): By email mark.bryan@hmrc.gsi.gov.uk or by phone +44 (0)20 7147 2684
• Robert Edwards (HMT): By email robert.edwards@hmtreasury.gsi.gov.uk.

HMRC will then make any necessary revisions and incorporate the guidance in the International Manual with the existing guidance on CFCs.

The Government is consulting on new Controlled Foreign Company (CFC) rules to be introduced in Finance Bill 2012. In the meantime, interim improvements to the existing CFC rules will be introduced in Finance Bill 2011.

If you are not already on the distribution list and would like to be informed of CFC updates then please email Robert Edwards.

The Government is consulting on the proposed package on CFC interim improvements.

The Government has published Corporate Tax Reform: Delivering a More Competitive System. Further information on this document is available on the Corporate Tax Reform page.

Parties interested in involvement in any part of the corporate tax reform consultation can find further information in the engagement strategy Chapter 5: The Corporate Tax Road Map.