The Controlled Foreign Companies (Excluded Banking Business Profits) Regulations 2012
These Regulations are made in exercise of the powers conferred by section 371FD of the Taxation (International and Other Provisions) Act 2010 (c. 8) (“TIOPA”). The Regulations provide that if certain conditions are met then no controlled foreign company (“CFC”) charge will arise under Chapter 6 of Part 9A of TIOPA in respect of the banking profits of the CFC. A CFC charge is a tax on a UK resident company which has an interest in a CFC.