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The controlled foreign companies鈥� rules provide a number of general exemptions. Where none of these are available these rules provide an additional mechanism for excluding profits from apportionment to a UK company.

The rules can apply in relation to any controlled foreign company that has individuals working for it in a business establishment in another EEA state. If the controlled foreign company鈥檚 profits would otherwise have to be apportioned, the UK owners of the controlled foreign company may apply to HMRC for the company鈥檚 apportionable profits to be treated as reduced by an amount (鈥渢he specified amount鈥�) representing the 鈥渘et economic value鈥� arising to the group that is created directly by the work of those individuals.

HMRC must grant the application providing the company鈥檚 application demonstrates that the specified amount satisfies the criteria set out in the new rules. Once the UK Company鈥檚 application has been granted, the controlled foreign company鈥檚 chargeable profits and creditable tax are treated as reduced for the purposes of determining the UK company鈥檚 controlled foreign companies鈥� charge.

The rules also provide a new 鈥渆ffectively managed鈥� condition in ICTA88/SCH25/PARA8 for the purposes of applying the Exempt Activities exemption to a controlled foreign company resident in another EEA state.