Further draft guidance on the new Controlled Foreign Companies (CFC) rules was published last month for comment comprising guidance on Chapters 2 (the CFC charge), 20 (residence) and 21 (management).

As readers will be aware, Finance Act 2012 contained the legislation for the new Controlled Foreign Companies (CFC) rules, and some amendments to the rules for the exemption of foreign permanent establishments that will apply to CFCs and permanent establishments with accounting periods that begin on or after 1 January 2013.

HMRC has been publishing draft guidance for the new rules at: - http://www.hmrc.gov.uk/drafts/cfc.htm. Initially the guidance will be published as separate documents for each chapter of Schedule 20 of Finance Act 2012 with updated drafts of the chapter guidance documents published once comments have been received. Once finalised, the guidance will then be incorporated into the International Manual in 2013.