HMRC have published draft regulations aimed at providing a safe harbour for CFCs with trading finance profits. The new CFC regime (introduced by Finance Act 2012) brings within its scope trading finance CFCs (such as banks) that have been excessively capitalized by a UK company or group. The CFC rules set out a mechanism for determining whether the trading finance CFC has been excessively capitalized. One must look to see whether it has an amount of capital that is appropriate to its commercial activities. Alternatively, one should check whether the CFC has been provided with excess capital from the United Kingdom. The...