CFCs and permanent establishments - draft guidance
HMRC is to publish draft guidance for the new Controlled Foreign Companies (CFCs) and permanent establishments rules. The Finance Bill 2012 contained the draft legislation for the new CFC rules, and some amendments to the rules for the exemption of foreign permanent establishments that will apply to CFCs and permanent establishments with accounting periods that begin on or after 1 January 2013.
Updated drafts of the chapter guidance documents will be published when there are enough comments and examples to incorporate into an updated guidance chapter. The guidance will then be incorporated into the International Manual in 2013.
More details are available from HMRC.
Published 26 October 2012
SOURCE: CCH Online