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

This file may not be suitable for users of assistive technology. Request an accessible format.

If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email digital.communications@hmtreasury.gsi.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.


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