Controlled foreign corporation
Controlled foreign corporation rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low taxed entities. The rules are needed only with respect to income of an entity that is not currently taxed to the owners of the entity. Generally, certain classes of taxpayers must include in their income currently certain amounts earned by foreign entities they or related persons control.
A set of rules generally defines the types of owners and entities affected, the types of income or investments subject to current inclusion, exceptions to inclusion, and means of preventing double inclusion of the same income. Countries with CFC rules include the United States, the United Kingdom, Germany, Japan, Australia, New Zealand, Brazil, Russia, Sweden, and many others. Rules in different countries may vary significantly.
Motivations
The tax law of many countries, including the United States, does normally not tax a shareholder of a corporation on the corporation's income until the income is distributed as a dividend. Prior to the first U.S. CFC rules, it was common for publicly traded companies to form foreign subsidiaries in tax havens and shift "portable" income to those subsidiaries. Income shifted included investment income and passive income, as well as sales and services income involving related parties. U.S. tax on this income was avoided until the tax haven country paid a dividend to the shareholding company. This dividend could be avoided indefinitely by loaning the earnings to the shareholder without actually declaring a dividend, because interest on the loans could be deducted and such interest payments would not be considered income. The CFC rules of Subpart F, and later of other countries' provisions, were intended to cause current taxation to the shareholder where income was of a sort that could be artificially shifted or was made available to the shareholder. At the same time, such rules were intended not to interfere with active business income or transactions with unrelated parties.Basic mechanisms
The rules vary, so this paragraph may not exactly describe a particular tax system. However, the features listed are prevalent in most CFC systems. A domestic person who is a member of a foreign corporation that is controlled by domestic members must include in such person's income the person's share of the CFC's subject income. The includible income generally includes income received by the CFC:In addition, many CFC rules treat as a deemed dividend earnings of the CFC loaned by the CFC to domestic related parties. Further, most CFC rules permit exclusion from taxable income of dividends paid by a CFC from earnings previously taxed to members under the CFC rules.
CFC rules may have a threshold for domestic ownership, below which a foreign entity is not considered a CFC. Alternatively or in addition, domestic members of a foreign entity owning less than a certain portion or class of shares may be excluded from the deemed income regime.
United States Subpart F rules
Enacted in 1962, these rules incorporate most of the features of CFC rules used in other countries. Subpart F was designed to prevent U.S. citizens and resident individuals and corporations from artificially deferring otherwise taxable income through use of foreign entities. The rules require that:- A U.S. Shareholder
- of a Controlled Foreign Corporation
- Their/its share of Subpart F Income of the CFC,
- Their/its share of aggregate income of 10% owned foreign corporations in excess of an aggregate return on depreciable tangible property of such 10% owned foreign corporations, and
- Their/its share of earnings and profits of the CFC that are invested in United States Property,
Each of the italicized terms above is defined:
Subpart F income includes the following:
but it does not include:
In addition, after 2017 10% U.S. shareholders of CFCs must include in their income currently their share of aggregate return on depreciable tangible assets in excess of 10% for CFCs in which they are shareholders. Corporations that are U.S. shareholders get to deduct 50% of this inclusion.
Corporate U.S. shareholders are entitled to a foreign tax credit for their share of the foreign income taxes paid by a CFC with respect to E&P underlying a Subpart F inclusion. Creditable taxes are reduced by 20% for §951A inclusions.
To prevent avoidance of Subpart F, U.S. shareholders of a CFC must recharacterize gain on disposition of the CFC shares as a dividend. In addition, various special rules apply.
United Kingdom rules
Controlled foreign company rules in the UK do not apply to individual shareholders, but otherwise they are similar to the U.S. rules. UK resident companies are subject to a charge for tax on undistributed income of low tax controlled foreign companies of which they are shareholders. Control for this purpose is not a mechanical test, rather one of factual control. However, control is considered to exist if the shareholder owns 40% or more of voting interests.A controlled company is a controlled foreign company if it is tax resident outside the UK and it is subject to a charge to tax less than it would have been were it a UK resident company. This is determined by comparing the actual charge to tax to a corresponding UK tax. In computing the corresponding tax, lower UK rates of tax on small companies are considered. Further, there are taken into account certain adjustments to income and fiscal years.
Certain exemptions apply. Generally, a foreign company will not be considered a controlled foreign company if it meets any of the following tests:
- It is tax resident in a "white list" of countries not considered to be tax havens, as maintained by HMRC,
- The foreign company maintains a policy whereby it distributed 90% or more of its available earnings each year,
- The company qualifies for a De Minimis level of accounting profits being less than £200,000. This level of income has been in place since 1 January 2011. Previously the level was set at £50,000 of profits that would be chargeable to UK corporation tax if the company were UK resident.
- The foreign company meets an active business test,
- The foreign company is publicly quoted on a recognized securities exchange, or
- The group meets a no-tax-reduction motive test.
German rules
- German residents control the non-German corporation and
- That corporation is taxed at a rate of less than 25% on the passive income.
Passive income is all income which is not active income, as extensively defined. Active income, however, excludes income where there has been substantial assistance by a German related party in earning the income. Active income also excludes all income of a foreign corporation lacking sufficient substance. Generally, passive income resembles U.S. foreign personal holding company income. However, deemed dividends may be exempted under some treaties.
India
The CFC Rules were first introduced in Indian taxation as part of the proposed Direct Tax Code 2010. The CFC provisions was also retained in revised draft of Direct Tax Code, 2013. However, Direct Tax Code is yet to become law in India and consequently, there are no statutory provisions in existing Income Tax Act for the enactment of CFC Rules.Other countries
taxes shareholders of foreign corporations where the operation of such corporation results in no or minimal foreign tax. However, there is a waiver where the foreign corporation conducts a substantial business.New Zealand and Sweden each have CFC rules, following a "grey list" and a "white list" approach, respectively.
Australia has CFC rules similar to UK rules, but relies more on a "white list" of safe countries.
Other anti-deferral measures
Several countries have adopted other measures aimed at preventing artificial deferral of passive or investment income. U.S. passive foreign investment companies require that shareholders in foreign mutual funds must include in their current taxable income their share of ordinary income and capital gains, or face a tax-and-interest regime.Avoiding CFC status
Under U.S. tax rules, a foreign entity may be classified for U.S. tax purposes as a corporation or a flow-through entity somewhat independently of its classification for foreign purposes. Under these "check-the-box" rules, shareholders may be able to elect to treat their shares income, deductions, and taxes of a foreign corporation as earned and paid by themselves. This permits U.S. individuals to obtain credits for foreign taxes paid by entities they own, which credits might otherwise not be available.Artificial arrangements to avoid CFC status may be ignored in some jurisdictions under legislative provisions or court-developed law, such as substance over form doctrines.
European civil law may provide opportunities for formalistic agreements whereby practical control is maintained but formal definitions of control are not met.