Have changes to the UK’s CFC rules created thousands of ‘surprise’ CFCs?

Policy background to the measure

The government’s statement at the time of the law change provided that: ‘The policy objective of this measure is to make sure the UK CFC rules continue to discourage potential tax planning by large multinational groups. The changes will comply with Council Directive (EU) 2016/1164 also known as the EU Anti-Tax Avoidance Directive (ATAD).’

The statement went on:

‘The current UK CFC measure of control takes into account interests held by UK resident associates or related parties of a chargeable company. The UK CFC control rules which are set out in chapter 18 part 9A TIOPA 2010 will be amended so that any interests held by associated enterprises wherever they are resident...