Commentary

D4.413 CFCs: low profits exemption

Corporate tax
Corporate tax | Commentary

D4.413 CFCs: low profits exemption

Corporate tax | Commentary

D4.413 CFCs: low profits exemption

A company with low profits is exempt from a CFC charge. Low profits are defined as1:

  1.  

    •     CFC accounting profits2 or total taxable profits3 of no more than £50,000, or

  2.  

    •     CFC accounting profits or total taxable profits of no more than £500,000 (of which no more than £50,000 represents non-trading income)

The above amounts are reduced proportionately if the accounting period is less than 12 months4.

This exemption does not however apply5:

  1.  

    •     where arrangements have been entered into at any time with the main purpose (or one of the main purposes) being to secure

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