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Finance Act 2012

Summary

1.Section 180 and Schedule 20 provide for a new regime for controlled foreign companies (CFC) to be inserted as Part 9A of the Taxation (International and Other Provisions) Act 2010 (TIOPA), and repeal the current CFC rules in Chapter 4 of Part 17 of the Income and Corporation Taxes Act 1988 (ICTA). The section and schedule also provide for the new regime to apply, with necessary adaptations, to the rules for foreign permanent establishments (PE) in Chapter 3A of Part 2 of the Corporation Tax Act 2009 (CTA 2009).

2.The new regime introduced by this section will have effect for accounting periods of CFCs beginning on or after 1 January 2013.

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