UK Controlled Foreign Company Reform: UK Government Announces Interim Changes to the Controlled Foreign Company Rules

Sullivan & Cromwell LLP - February 2, 2011

On 29 November 2010, the UK Government published further consultation documents regarding the reform of the UK Controlled Foreign Company (“CFC”) rules. Interim changes to the CFC rules were initially announced on 27 July 2010, and were further detailed in the publication of 29 November 2010. Draft legislation enacting the interim changes was published on 9 December 2010, and will form part of the UK Finance Bill 2011. The impact of these interim changes is expected to be limited, despite their relative complexity.