Martin Lambert and Zoe Wyatt provide a practical guide to what the CFC reforms will mean for multinationals.
The controlled foreign company (CFC) reform is for now complete; enacted in FA 2012 and codified in the TIOPA 2010 Part 9A it is effective for accounting periods beginning on or after 1 January 2013.
While the final legislation is an improvement on the earlier consultation drafts the rules remain fiercely complex and we still await full and final HMRC guidance in respect of a substantial part of the new regime (the draft partial guidance is available at lexisurl.com/9KgI6). The purpose of this article is to create a quick reference guide that will help navigate the provisions that will most commonly be used. It begins with a comparison table of the old (found in ICTA 1988 Part 17 Chapter 5 and Sch 25) and new rules followed...
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Martin Lambert and Zoe Wyatt provide a practical guide to what the CFC reforms will mean for multinationals.
The controlled foreign company (CFC) reform is for now complete; enacted in FA 2012 and codified in the TIOPA 2010 Part 9A it is effective for accounting periods beginning on or after 1 January 2013.
While the final legislation is an improvement on the earlier consultation drafts the rules remain fiercely complex and we still await full and final HMRC guidance in respect of a substantial part of the new regime (the draft partial guidance is available at lexisurl.com/9KgI6). The purpose of this article is to create a quick reference guide that will help navigate the provisions that will most commonly be used. It begins with a comparison table of the old (found in ICTA 1988 Part 17 Chapter 5 and Sch 25) and new rules followed...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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