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On September 12, 2012, the United Kingdom became the first government to enter into an agreement (the "Agreement") with the United States regarding the U.S. withholding tax regime commonly referred to as the Foreign Account Tax Compliance Act ("FATCA"
The UK's controlled foreign companies rules are designed to ensure that certain UK-controlled companies cannot shelter their profits offshore, in low tax jurisdictions, thereby minimising the actual profits subject to UK tax
