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Controlled foreign companies making a designated currency election

A controlled foreign company (CFC) is defined in ICTA88/S747 as a company which in an accounting period is resident outside the United Kingdom, controlled by persons resident in the United Kingdom, and subject to a lower level of taxation in its territory of residence

More information on CFCs can be found at INTM201060.

A UK resident company (or companies that have a majority interest in a CFC may make a designated currency election on behalf of the CFC (ICTA88/SCH24/PARA4(2C)). Where such an election is made the CFC will be deemed to have made the election which will take effect from the date specified in the election. »Ê¹ÚÌåÓýapp election must be made in advance of the date on which it is to take effect.

»Ê¹ÚÌåÓýapp extended time limits for claims upon which relief is dependant made on behalf of CFCs under ICTA88/SCH24/PARA4(1) do not apply to a designated currency election under CTA10/S9A.