Commentary

D4.410 Overview of CFC exemptions

Corporate tax
Corporate tax | Commentary

D4.410 Overview of CFC exemptions

Corporate tax | Commentary

Full exemptions from CFC regime

D4.410 Overview of CFC exemptions

A great many companies resident outside the UK are within the definition of a CFC (see D4.402) but the legislation provides that where specified conditions are satisfied, no assessment or apportionment of the chargeable profits of the CFC can be made.

The current exclusions are as follows:

  1.  

    •     the exempt period of exemption; see D4.4111

  2.  

    •     the excluded territories exemption; see D4.4122

  3.  

    •     the low profits exemption; see D4.4133

  4.  

    •     the low profit margin exemption; see D4.4144; and

  5.  

    •     the tax exemption; see D4.4155

If any one of these tests

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