Controlled Foreign Companies (CFC) Working Groups

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These working groups formed part of the UK government's consultation and review of the options to reform the UK’s Controlled Foreign Companies (CFC) rules, which were introduced in the Finance Bill 2012.


From the HM Treasury website:

Working Groups of representatives from businesses have been established to complement wider consultation on CFC reform and to discuss options and proposals in more detail. Lists of members are provided below. The first working group meetings were scheduled for January 2011.[1]

CFC Monetary Assets working group

CFC intellectual property working group

   Colin Garwood – Intercontinental Hotels
   Linda Cutler – Kraft
   Helen Jones – GlaxoSmithKline 
   Paul Morton – Reed Elsevier 
   Chatan Patel – Cable and Wireless 
   Robin Booth – Association of British Food 
   Simon Upcott – Cookson

CFC Property working group

   Lucinda Bell – British Land
   Neil Stanford – Standard Life
   Octavia Peters – Segro
   Terry O'Beirne – Capital and Counties 
   Will Chetwood – Aviva 
   Jeremy Moore – Grosvenor

CFC Insurance working group

   Roger Adams – Aviva 
   Rob Clayton – RSA 
   Mervin Skeet – XL Group 
   Kieran Devlin – Prudential 
   Juliet Philips – Lloyds 
   Rob Gill - AIG

CFC Banking working group

CFC interim improvements

Secondee from Big Four accountancy firm works on CFC reform

In March 2012 the Guardian reported that Robert Edwards, a senior manager in international corporate tax from accountants KPMG, was seconded to the Treasury for 20 months to see through developing the policy on CFC rules. His speciality at KPMG was described as "advising [large] multinationals on tax-efficient cross-border financing and restructuring". [2]According to Edwards's current LinkedIn profile, he "played a pivotal role in CFC reform in shaping the new regime and working closely with HMRC on technical issues and the development of the detailed rules". Edwards now "advises multinationals on the application of the CFC rules and financing opportunities under the new CFC regime".[3]

External resources



  1. Controlled Foreign Companies (CFC) reform, 29 November 2010, acc 6 October 2011
  2. Felicity Lawrence, Britain's tax rules – now written for and by multinationals, The Guardian, 19 March 2012 21.45 GMT
  3. Robert Edwards, LinkedIn, accessed 14 June 2013