This article aims to help the reader navigate the upcoming changes to the controlled foreign company (CFC) rules, applicable to CFCs for accounting periods beginning on or after 1 January 2013. The article compares the new CFC rules (TIOPA 2010 Part 9A) with the old (found in ICTA 1988 Part 17, Chapter 5 and Sch 25) in tabular format through the use of a case study, together with a decision tree and suggested road map through the business profits gateways.
