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A controlled foreign company ("CFC") is a company controlled by a UK resident that is not itself UK resident and is subject to a lower rate of tax in the territory in which it is resident. Under certain circumstances, UK resident companies that control a CFC pay corporation tax on what the UK tax profits of that CFC would have been.
A non-domiciled UK resident earning less than £2,000 in a year outside the UK does not pay tax on this unless it is transferred to the UK. This would apply to the typical person taking up a temporary job in the UK, being paid, and paying tax on it, in the UK, with possible additional small earnings in the home country.
In any accounting period, a company may pay a form of corporate income tax on its taxable profit which reduces the amount of post-tax profit available for distribution by dividend to shareholders. In the absence of a participation exemption, or other form of tax relief, shareholders may pay tax on the amount of dividend income received.
Under certain circumstances, UK resident companies that control a CFC pay corporation tax on what the UK tax profits of that CFC would have been. However, because of a wide range of exemptions, [217] very few companies suffer a CFC charge. [citation needed] Schedules B, C and E used to, but no longer, exist. [citation needed]
A recipient of a fully franked dividend on the top marginal tax rate will effectively pay only about 15% tax on the cash amount of the dividend. In effect, when distributed as dividends, the profits of a corporation are taxed at the average of the shareholders' marginal tax rates; otherwise they are taxed at the corporate tax rate.
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Dividend imputation was introduced in 1987, one of a number of tax reforms by the Hawke–Keating Labor Government. Prior to that a company would pay company tax on its profits and if it then paid a dividend, that dividend was taxed again as income for the shareholder, i.e. a part owner of the company, a form of double taxation.
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