Controlled Foreign Companies Reform: How the Proposed New Rules Interact with Transfer Pricing Legislation

On 26 January 2010 HM Treasury and HM Revenue & Customs (HMRC) issued their long-awaited discussion document setting out proposals for a reformed controlled foreign company (CFC) regime. This article examines some of the current ways these CFC and transfer pricing regimes interact, and the new potential interactions arising as a result of the CFC proposals.