Commentary

D4.412 CFCs: excluded territories exemption

Corporate tax
Corporate tax | Commentary

D4.412 CFCs: excluded territories exemption

Corporate tax | Commentary

D4.412 CFCs: excluded territories exemption

A CFC will be excluded from the CFC charge if1:

  1.  

    •     the company is resident and carries on business in an excluded territory as specified in SI 2012/3024.

  2.  

    •     the total of the CFCs relevant income (see below) does not exceed the 'threshold' amount of 10% of the CFC's accounting profits, excluding transfer pricing adjustments, for the accounting period in question, or £50,000 if greater (reduced proportionately if the accounting period is less than 12 months) 2;

  3.  

    •     the IP condition is met (see below), and

  4.  

    •     the CFC is not involved in an arrangement, the main purpose or one of the main purposes of which is to obtain a tax advantage 3 for any person at any time during the accounting

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