Impact of CFC reform

Speed Read: The recently published CFC proposals have been broadly welcomed, but there is still a lot of work to be done before we have a workable set of rules. The scope of the redesigned exempt activities and motive tests will be key to allowing UK groups to structure their operations in the most efficient way commercially without falling foul of the rules. However, with a new government it is currently unclear what will happen in terms of the direction and timing of the CFC reform and, in particular, the current proposals. We should get more details on this in the forthcoming Budget.