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Controlled foreign companies: HMRC settlements

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The total recorded yield from HMRC settlements relating to controlled foreign companies legislation in the financial years 2007/08 to 2009/10 is estimated at £719 million, David Gauke said in a Commons written answer.

Six settlements yielded more than £10 million each in 2009/10. It is difficult to give precise answers concerning CFC inquiries, Gauke said, because they are often part of a wider investigation, and settlement of a CFC dispute may be included in an overall settlement figure.

He added: ‘The amount of tax at risk in respect of any UK company with a holding in a CFC depends on the facts and until an inquiry is completed cannot be more than an estimate. As the facts are established during the course of an inquiry, the tax at risk in any case fluctuates as the inquiry proceeds.’