Policy paper

Controlled foreign companies: loss restriction

This measure affects the loss relief of large UK multinational companies with overseas subsidiaries.


Controlled Foreign Companies: loss restriction

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This measure stops losses and other surplus expenses from being set off against the CFC charge on the profits of controlled foreign companies (CFCs). A CFC charge arises to a UK company in relation to profits from its CFCs which have been diverted from the UK. The measure applies to profits which arise on or after 8 July 2015.

Published 8 July 2015