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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Foreign exchange: accounts drawn up in a foreign currency: designated currency election: controlled foreign companies

Controlled foreign companies making a designated currency election

A controlled foreign company (CFC) is defined in ICTA88/S747 as a company which in an accounting period is resident outside the United Kingdom, controlled by persons resident in the United Kingdom, and subject to a lower level of taxation in its territory of residence

More information on CFCs can be found at INTM201060.

A UK resident company (or companies that have a majority interest in a CFC may make a designated currency election on behalf of the CFC (ICTA88/SCH24/PARA4(2C)). Where such an election is made the CFC will be deemed to have made the election which will take effect from the date specified in the election. The election must be made in advance of the date on which it is to take effect.

The extended time limits for claims upon which relief is dependant made on behalf of CFCs under ICTA88/SCH24/PARA4(1) do not apply to a designated currency election under CTA10/S9A.