Designer rates for controlled foreign companies (CFCs)

Regulations SI 2000/3158 have been laid before the House of Commons. These list the overseas tax regimes which are to be regarded as designer rates regimes for the purposes of the CFC rules. The listed regimes, which have been used to circumvent the UK’s anti-avoidance rules for CFCs, are in Guernsey, Jersey, the Isle of Man and Gibraltar. Finance Act 2000 enacted the ability to make these Regulations, which follow on from the Government’s October 1999 announcement that it intended to counter the use of designer rate regimes.