Our submission and the CFC guidance overview, draft regulations and Chapters 3,4,5 and 9 are all available here in Adobe (pdf) format.
Background
HMRC has published draft regulations which provide the list of excluded territories for the purposes of the ETE and set out a simplified ETE that is available for CFCs in Australia, Canada, France, Germany, Japan and USA. The simplified ETE is intended to allow groups to deal quickly with CFCs in these territories, which are major trading partners that have tax regimes broadly equivalent to the UK’s. The simplified ETE is an additional, optional basis for exemption that will not affect entitlement to ETE under the normal rules.
The draft regulations for the ETE and explanatory memorandum are attached and are also available at http://www.hm-treasury.gov.uk/controlled_foreign_companies.htm
CFC draft guidance
Also attached is the draft guidance on the Gateway, chapters 3, 4 and 5 and also on exemptions for profits from qualifying loan relationships, chapter 9.
Technical Team
25 September 2012
