Commentary

D4.435 Determining the CFC charge

Corporate tax
Corporate tax | Commentary

D4.435 Determining the CFC charge

Corporate tax | Commentary

Calculating the CFC charge

D4.435 Determining the CFC charge

Where there are profits that pass through the CFC charge gateway, the CFC charge is determined in accordance with a series of steps1. These are used to work out whether or not a charge arises and, if it does, which UK resident companies are chargeable. In outline the steps are as follows2:

Step 1: determine the persons who have relevant interests in the CFC during the accounting period (D4.436). The CFC charge only apples to companies that are UK resident during the accounting period when it has a relevant interest in

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