The following flowchart provides a guide to the proposed CFC regime based on the 31 January 2012 draft legislation and HM Treasury & HMRC's January 2012 Update Note.
Note: The flowchart provides a broad overview only. There are a number of detailed rules (including targeted anti-avoidance) included in the draft legislation which are not set out here. The use of square brackets in the flowchart indicates that draft legislation for that measure has not yet been published but the government has indicated its position.
The draft legislation Update Note and additional HM Treasury and HMRC materials are available via www.lexisurl.com/St13a.
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