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UK Tightens CFC Rules

by Robin Pilgrim, LawAndTax-News.com, London

09 February 2005

Changes to the UK's controlled foreign companies (CFCs) legislation trailed by Chancellor Gordon Brown in his pre-Budget report last year have been presented to the House of Commons, according to reports.

The 2005 Controlled Foreign Companies (Excluded Countries) (Amendment) Regulations aim to prevent CFCs from manipulating their profit location in order to evade taxes, to stop them from secreting income in non-corporate entities, and to exclude them from receiving the benefits of the CFC regime if they are not liable for tax in another country.

The measures are set to come into full force on March 31st.

Speaking to the LMG news service, a spokesman for the Inland Revenue explained that:

"All of the changes made are a reaction to schemes including some that were identified via the disclosure rules. The government could not have allowed significant amounts of tax to remain at risk."

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