Commentary

D4.425 Overview of the CFC gateway

Corporate tax
Corporate tax | Commentary

D4.425 Overview of the CFC gateway

Corporate tax | Commentary

The CFC gateway

D4.425 Overview of the CFC gateway

The gateway essentially operates to filter out CFC profits which will be liable to the CFC charge. Only CFC assumed total profits (see D4.420) which pass through the CFC charge gateway are liable to the CFC charge. There are five gateways which must all be considered, as follows:

  1.  

    •     profits attributable to UK activities (D4.426)1

  2.  

    •     non-trading finance profits (D4.427)2

  3.  

    •     trading finance profits (D4.428)3

  4.  

    •     captive insurance business (D4.429)4; and

  5.  

    •     solo consolidation (D4.430)5

In addition there are certain exemptions for profits from qualifying loan relationships which apply

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