HMRC update guidance on Controlled Foreign Companies and tax avoidance

Released 10 October 2018

HMRC have updated guidance on Controlled Foreign Companies (CFCs) to reflect a new address for requesting further guidance from HMRC on a particular CFC case.

Find out about Controlled Foreign Companies and tax avoidance provides information on rules to stop companies from reducing UK tax by diverting profits to tax shelters and preferential regimes, and the exemptions. The CFC rules are anti-avoidance provisions designed to prevent diversion of UK profits to low tax territories. If UK profits are diverted to a CFC, those profits are apportioned and charged on a UK corporate interest-holder that holds at least a 25% interest in the CFC. The regime operates by applying a series of charge gateways to different types of profits and there are also a number of entity level exemptions. Further guidance from HMRC on a particular CFC case can be obtained by email to cfcs.mailbox@hmrc.gsi.gov.uk or by writing to:

HM Revenue and Customs
Business Assets and International
Base Protection Policy Team
S1715, Floor 9, Mail Point 3
Central Mail Unit
Newcastle
NE98 1ZZ

View the updated guidance Find out about Controlled Foreign Companies and tax avoidance.

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