In his recent Autumn Statement, the Chancellor announced a proposal to strengthen the Controlled Foreign Company
rules, which will be put to Parliament in the 2014 Finance Bill.
Richard Fenton The Chancellor confirmed that he would modernise the Controlled Foreign Company
legislation, to take effort from 1 January 2013, with draft legislation previously issued simplified further to address companies' needs for simpler administration of this complex legislation.
Dixons, Kingfisher and Carphone Warehouse all saw their shares fall as they revealed how changes to Controlled Foreign Company
legislation would hit home.
FEE's newly-released position paper on Controlled Foreign Company
Legislations in the EU consists of a comprehensive study of tax laws regarding Controlled Foreign Companies (CFC), and it considers how CFC rules are structured and applied by individual EU Member States.
A further update on the controlled foreign company
legislation (anti-avoidance legislation aimed at taxing in the UK, profits that have been artificially diverted from the UK to an overseas country).
This is clearly illustrated by the announcement in the PBR to introduce changes to the way in which the UK taxes income of certain overseas subsidiaries of UK groups - the so called Controlled Foreign Company
These raised tax through tightening the controlled foreign company
and double tax relief rules, as well as introducing disallowance of interest expense in certain multinational investment structures.