Controlled Foreign Companies (CFCs) – Requirements for UK Companies
Written by Tax Partner, Thomas Adcock The CFC rules are designed to protect against international groups diverting profits to non-UK jurisdictions. The CFC rules will only apply if the UK company has more than a 25% interest in an overseas company. However, importantly, the CFC legislation includes a number of exemptions which most international […]
Hybrid Mismatch Rules: Requirements for UK companies to consider their cross-border transactions and structure
Written by Tax Partner, Thomas Adcock Put simply, the hybrid mismatch rules (as they are known) are there to make the global tax system fairer. They do this in two ways: By ensuring that where a company within the group gets a deduction for an intra-group payment, that the recipient company is taxed […]