On 28 September 2012, HM Revenue & Customs (HRMC) published additional draft guidance on controlled foreign companies (CFCs) and permanent establishments (PEs) in relation to the new CFC legislation contained in Finance Act 2012. The additional and existing draft guidance is available in the HMRC website. HMRC intends to consult on draft guidance for CFCs and PEs throughout the remainder of 2012. However, HMCR would prefer substantive comments to be made by the end of October 2012 so that comments can be properly considered before the draft guidance is incorporated into the International Manual in January 2013. Comments on the draft...