Commentary

D4.430 CFC gateway: solo consolidation

Corporate tax
Corporate tax | Commentary

D4.430 CFC gateway: solo consolidation

Corporate tax | Commentary

D4.430 CFC gateway: solo consolidation

It is necessary to firstly establish in what situations this gateway test applies and then if it does, the extent to which profits pass through the gateway. Only profits which pass through the gateway are potentially liable to the CFC charge.

Establishing whether the test applies

This gateway test applies if one or more of the following conditions are met1:

  1.  

    (a)     at any time in the period the CFC is a subsidiary undertaking which is the subject of a solo consolidation waiver under section BIPRU 2.1 of the handbook made by the PRA Rulebook, and the

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