Commentaries

Tax Memo


 CHAPTER 10  Overseas issues 


 SECTION 1   Controlled foreign companies 

 A.  Why have special rules? 
Rattachements 747,
 
Sch 24 ICTA 1988

 
2145
To prevent international groups of companies generating and retaining profits in low tax jurisdictions, legislation exists to apportion profits of controlled foreign companies (CFCs) back to the UK and charge tax at the main UK corporation tax rate (although the tax charged is not corporation tax as such).
Over the past few years the r...

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