The purpose of the exempt period exemption (EPE) is to provide a 'new' CFC with a grace period during which it can organise or reorganise its business so that a CFC charge does not arise, and to give the acquiring group's tax department sufficient time to complete their analysis of the new subsidiaries' affairs and make any necessary changes such that a charge does not arise in the future.
In practice, the usefulness of this grace period is somewhat limited by the requirements of the rules.
The EPE operates by providing that for a period of 12 months, a foreign subsidiary may be exempt from the CFC rules,
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 15:49