The United Kingdom has new legislation on the taxation of Controlled Foreign Corporations.1 In January 1981 the U.K. Board of Inland Revenue published two consultative documents, one on Tax Havens and the Corporate Sector and the other on Company Residence, to xvhich comments were invited.2 The U.K. Government next authorized the publication of draft legislation with a view to further consultations. This was done by a document dated November 1981, in which the broad objective was stated to be to produce to counter international tax avoidance by U.K. Companies. The topics covered by the November 1981 draft were (i) company residence (chapter 1), (ii) tax haven companies (chapter 2), (iii) out of income by overseas subsidiaries to U.K. parent companies, referred to as upstream loans (chapter 3). There was substantial opposition to these proposals from the business and financial community, and a new document was issued in December 1982. This document proposed measures to counter the use of controlled foreign companies in low tax countries where avoidance of U.K. tax was the main, or one of the main, purposes of the activities. It contained draft clauses which would enable a charge to corporation tax to be imposed on certain U.K. companies with at least a 10% interest in foreign companies under U.K. control but resident in a low tax country.3 The Government decided not to proceed with a statutory definition of company residence, but stated an intention to bring forward specific measures to deal with arrangements which take advantage of the current company residence rules. It also de-