Controlled Foreign Corporation

Meaning of Controlled Foreign Corporation

A foreign business entity registered and carrying out its business function in a country other than its resident country is termed a Controlled Foreign Corporation (CFC). In the US, a controlled foreign corporation is defined as per the shares held by the citizens of their country.

Since a CFC is a foreign company, it means that the company should not be a tax resident in the foreign country in which it is operating. Let us understand more about CFC and its taxability.

Controlled Foreign Corporation and Taxability

The introduction of the CFC concept was mainly to prevent evasion of tax. There was a time when many forge companies were set up in tax havens to claim tax benefits. CFC structure overcomes this flaw. The CFC structure of each country now looks at the taxation of each company and the diversion of their earnings. This structure targets the MNCs and their individuals to keep a check on their tax filings. With the establishment of the CFC structure, tax evasion has come down significantly in different countries. Visit “Types of Foreign Exchange Exposure” and “International Finance Management.”

Controlled Foreign Corporation


After globalization, multinational groups have always been looking for business beyond their geographical boundaries. They look for establishing a business in countries with less taxation jurisdiction. This has often led to tax evasion by such multinational firms. The introduction of the CFC concept was to curb this unfair practice. Each country has its own CFC structure. In addition, most countries are successful in implementing it. The tax department of different countries is now more active in the controlling interest of a business and its individuals. To sum up, the CFC structure has been successful in preventing tax evasion, and in the future, the structure will get stronger.

Sanjay Borad

Sanjay Bulaki Borad

Sanjay Borad is the founder & CEO of eFinanceManagement. He is passionate about keeping and making things simple and easy. Running this blog since 2009 and trying to explain "Financial Management Concepts in Layman's Terms".

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