Controlled foreign company (CFC) rules
Broadly where a non UK-resident company is controlled by a UK person and the tax it pays overseas is less than 75% of what it might have been in UK resident, then there may still be a tax liability in the UK, subject to various exemptions.
Under corporation tax self-assessment (CTSA)1, there is a requirement to include CFC charges in a supplementary page of the CTSA return, and the information supplied in the return will provide the starting point for any CFC enquiry. HMRC are entitled to enquire into entries in the supplementary page of the company's return as regards such a liability and to request
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Web page updated on 17 Mar 2025 17:16