FA 2012 introduced new rules (TIOPA 2010 Part 9A Chapters 1–22), which modernised the UK’s nearly 30 year old CFC regime and will apply to groups for accounting periods starting after 1 January 2013. These rules have been in development for a number of years but the hope is that we now have a more user friendly and competitive system. The rules have a series of gateways and entity level exemptions. The hope is that once we have lived with the regime for a while the complexities in the new rules do not detract too much from the clear improvements it makes.
