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Tax chargeReviewed October 2026
A foreign subsidiary whose profits may be attributed back to, and taxed in, the parent’s home country under anti-avoidance rules. CFC regimes are designed to stop profits being shifted into low-tax jurisdictions.
In the UK the regime sits in the Taxation (International and Other Provisions) Act 2010, and a charge can arise where a UK-resident company controls a low-taxed foreign subsidiary, subject to a set of statutory exemptions.
A definition of an established legal or tax concept for general information. It is not advice on any individual situation.
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