On 30 June 2011, the government published the long-awaited consultation document on reform of the controlled foreign companies (CFC) legislation. The consultation follows the announcement at Budget 2011 that the government would consult on full reform this year with new legislation to be included in the Finance Bill 2012.
The regime has been repeatedly criticised as being an impediment to the competitiveness of the UK’s tax system. Indeed, the government’s stated aim for reform is creating a more competitive regime, while providing adequate protection of the UK’s corporation tax base. Continue reading “Full reform of the controlled foreign companies legislation”