Finance Act 2024

Controlled foreign company tax regimes U.K.

18 (1) Section 179 (controlled foreign company tax regimes) is amended as follows.

(2) In subsection (1), in paragraph (b), for “controlled foreign company” substitute “CFC entity”.

(3) In subsection (4), after the definition of “controlled foreign company tax regime” insert—

• ““CFC entity”, in relation to a member of a multinational group who is subject to a controlled foreign company tax regime, means—

  (a)

  a controlled foreign company in relation to that member,

  (b)

  a permanent establishment of such a controlled foreign company, or

  (c)

  an entity whose profits are treated, for the purposes of the regime, as the profits of such a controlled foreign company;”.

(4) In section 180 (blended CFC regimes)—

(a) in subsection (2)(b), omit “blended”,

(b) in subsection (4), omit “blended” in the third place it occurs,

(c) in subsection (5)—

(i) in the words before paragraph (a), omit “blended” in the second place it occurs, and

(ii) in paragraph (b), omit “blended”,

(d) in subsection (6)(a), omit “blended”,

(e) in subsection (8)—

(i) in the words before paragraph (a), omit “blended”, and

(ii) in paragraph (b), in the words before sub-paragraph (i), omit “blended”, and

(f) omit subsection (10).

(5) In Schedule 17 (index of defined expressions), in the table, at the appropriate place insert—

“CFC entity

section 179(4)”.