Recent updates to HMRC’s International Manual concerning Controlled Foreign Companies.
HMRC are updating the Controlled Foreign Companies (CFCs) section of their International Manual. The changes relate to the finance company exemptions, which exclude from the CFC regime certain profits of a CFC from its ‘qualifying loan relationships’. The changes update the examples and guidance relating to a number of different areas of this guidance.
The UK CFC regime includes a finance company exemption which provides for a partial or complete exemption of profits from qualifying loan relationships.
Changes made to HMRC guidance include additional guidance on the following:
Some of the changes are to update the format to make this easier to read. It is not yet clear whether changes of substance are being made.
For further information please contact: