CFC reform – a Gateway update - CIOT comments
The CIOT comments, sent to HRMC on 16 March 2012, on this update to the Controlled Foreign Companies (CFC) reform consultation, which includes what HMRC hope to be an improved Gateway test.
As well as our submission, please find attached an update on CFC reform and draft legislation which includes what HMRC/HMT hope is an improved Gateway test. All documents are available in Adobe (pdf) format.
Due to the reordering of chapters to give more prominence to the Gateway test HMRC have not provided a compare version with changes underlined, however they say that no changes have been made other than those detailed in annex A of the update document.
These documents are also published at http://www.hm-treasury.gov.uk/controlled_foreign_companies.htm.
16 March 2012