Business tax – guidance

Controlled Foreign Companies: supplementary guidance

Supplementary guidance on Section 371IH(9A) to (9E) of Part 9A TIOPA 2010 for Controlled Foreign Companies (CFCs) with accounting periods beginning on or after 1 January 2013.

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Guidance on the Finance Act 2014 additions to the CFC rules at Section 371IH(9A) to (9E) of Part 9A TIOPA 2010 was first published on 17 April 2014 and can be found on the National Archives website along with guidance relating to the rest of the CFC rules.

This supplementary guidance was published on 17 November 2014 to provide clarity on the impact of the Organisation for Economic Co-operation and Development (OECD) /G20 base erosion profit shifting (BEPS) project, or potential changes in US tax laws, on businesses with existing tower structures.

The International Manual will shortly be updated to include guidance on the CFC rules for CFCs with accounting periods beginning on or after 1 January 2013.