Controlled Foreign Companies - Tests, Tax & Tricky Aspects

Introduction

This virtual classroom seminar will explore the trickier aspects of Controlled Foreign company (‘CFC’) rules and the features of this income tax system which is designed to limit artificial deferral of tax by using offshore low taxed entities.

The Anti-Tax Avoidance Directive (ATAD) has been implemented, prescribing changes to CFC rules. The Finance Act 2019 introduced amendments to the UK CFC rules in order to comply with ATAD.

This intermediate level virtual classroom session will examine the UK CFC legislation and highlight points that need to be considered during cross-border corporate transactions.

What You Will Learn

This live and interactive session will cover the following:

• Control test - the 1 January 2019 changes
• CFC Charge Gateways
• Initial Gateway
• Main Gateways - profits attributable to UK activities; non-trading finance profits; trading finance profits; captive insurance business; solo consolidation
• Exemptions - profits from qualifying loan relationships; exempt period; excluded territories; low profits; low profit margin; tax
• Chargeable profits
• Chargeable companies - exceptions for special types of companies
• The CFC Charge and how it is charged
• CFCs, BEPS and the post-Brexit era

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.