Martin Lambert and Zoe Wyatt provide a practical guide.
The current wholesale CFC reform includes the much anticipated finance company partial exemption (FCPE) that will result in a non-trading finance CFC having only 25% of its profit apportioned to its UK parent. It is expected that the new CFC rules including the FCPE will have effect for accounting periods of CFCs commencing on or after 1 January 2013.
The proposed changes to the UK CFC regime provide an opportunity for a UK multinational group to reap the benefits of locating a group finance company overseas; typically in territories such as Belgium Cyprus Ireland ...
