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CFCs And Motive Test

Heather Self Group Tax Director with Scottish Power plc reviews the Revenue's guidance on the motive test for CFCs focussing particularly on the issues facing captive insurance companies
In February 2003 the Special Commissioners released their judgment in the case of Association of British Travel Agents Limited (ABTA) v CIR (Sp C 359). This was the first time that the Courts had considered the interpretation of the motive test under the 1984 Controlled Foreign Companies (CFC) legislation. Shortly afterwards the Inland Revenue published its draft guidance on the motive test and this was finalised in March.
This article reviews the Revenue's guidance and compares it to the Special Commissioners' decision. It...

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