UK: corporate tax reform - consultation on proposed controlled foreign company rules

HM Treasury has published detailed proposals setting out how the UK's new controlled foreign companies tax regime will operate: see here (pdf). The intention is that the new rules will be included in the Finance Act (2012). Further background information is available here. In making changes to the regime, the Government's objectives are to: [a] target and impose a CFC charge on artificially diverted UK profits, so that UK activity and profits are fairly taxed; [b] exempt foreign profits where there is no artificial diversion of UK profits; and [c] not tax profits arising from genuine economic activities undertaken offshore.