HM Treasury has published a ‘non-exhaustive list’ of changes made to draft legislation on controlled foreign companies between the February 2012 update and the Finance Bill published on 29 March.
A detailed explanation (running to 90 pages) of clause 180 and Sch 20 to the Finance Bill is set out in the Explanatory Note published with the Bill, and reflects all changes made since the draft legislation was first published last December.
More information is provided on the CFCs working groups and committees page of the Treasury website, including minutes of a recent meeting of the CFCs TAARs [targeted anti-avoidance rules] working group. The minutes note that the use of separate TAARs for specific parts of the regime was ‘preferred to a single anti avoidance rule covering the CFC regime as a whole’.
HMRC guidance
Deloitte said it understood that ‘some important parts of the draft guidance’ on CFCs would be circulated for comment in late spring. ‘Comprehensive draft guidance will be published around the time of Royal Assent to the Finance Act, and will be open to consultation until about the end of the year.’
HM Treasury has published a ‘non-exhaustive list’ of changes made to draft legislation on controlled foreign companies between the February 2012 update and the Finance Bill published on 29 March.
A detailed explanation (running to 90 pages) of clause 180 and Sch 20 to the Finance Bill is set out in the Explanatory Note published with the Bill, and reflects all changes made since the draft legislation was first published last December.
More information is provided on the CFCs working groups and committees page of the Treasury website, including minutes of a recent meeting of the CFCs TAARs [targeted anti-avoidance rules] working group. The minutes note that the use of separate TAARs for specific parts of the regime was ‘preferred to a single anti avoidance rule covering the CFC regime as a whole’.
HMRC guidance
Deloitte said it understood that ‘some important parts of the draft guidance’ on CFCs would be circulated for comment in late spring. ‘Comprehensive draft guidance will be published around the time of Royal Assent to the Finance Act, and will be open to consultation until about the end of the year.’
