Introduction

The CFC rules as outlined in this note apply to accounting periods beginning on or after 1 January 2013, the date upon which significant changes made by Finance Act 2012 became effective.

From this date, the CFC rules also apply to foreign branches in respect of which an exemption election has been made.

The rules are complex and this guidance note outlines the main provisions only.

HMRC guidance on the CFC regime is available at INTM190000 onwards.

Pre 1 January 2013 regime

As mentioned above, significant changes to the CFC regime were introduced by Finance Act 2012. For further details of the old CFC regime, please see Simon's Taxes, D4.3 (subscription sensitive). This could be relevant in the context of dealing with enquiries into corporation tax returns for accounting periods ending prior to the changes in legislation.

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