UK Controlled Foreign Company Reform: Further Draft Legislation on Permanent Changes to the CFC RulesSullivan & Cromwell LLP - February 6, 2012
The UK government has published revised draft legislation for a reformed controlled foreign company (“CFC”) code. This includes:
- revised drafting for finance company exemptions, including a full exemption in some cases; and
- new drafting to apply the CFC rules to UK companies with exempt foreign branches.
The government has also published a consultation update, setting out its direction of travel on:
- safe harbours for banks and insurers from the special rules for finance profits;
- a temporary period exemption; and
- commencement of the reformed regime.