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Controlled foreign companies (CFCs)—overview
D4.401 Controlled foreign companies (CFCs)—overview
Why is the CFC regime in place?
Setting up a company overseas and keeping it outside the charge to UK corporation tax is very popular tax planning for companies. The controlled foreign companies (CFCs) regime1 is a set of anti-avoidance measures which aims to counter such planning. It applies to accounting periods of CFCs which begin on or after 1 January 20132.
The rules seek to prevent UK resident companies setting up subsidiaries abroad with a view to diverting and keeping profits outside the UK tax net. Normally the subsidiary will be set up in a low tax or no tax territory. Where an overseas company is a CFC, generally speaking, its chargeable profits will be attributed to its UK corporate shareholders (provided they own at least a 25% interest in the CFC) so that they
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