The profits of UK owned captives, that are based overseas, may be subject to UK tax under the current UK Controlled Foreign Companies (CFC) legislation. However, going forward, following the announcement by the Chancellor in his Autumn Statement dated 6 December 2011, there will be a complete overhaul of the CFC legislation. The Government has published draft legislation to be included in the Finance Bill 2012. The new rules will be effective for accounting periods beginning on or after the Finance Bill 2012 receives Royal Assent – expected to be sometime in the Summer of 2012.