Commentary

D4.439 CFCs: chargeable companies

Corporate tax
Corporate tax | Commentary

D4.439 CFCs: chargeable companies

Corporate tax | Commentary

D4.439 CFCs: chargeable companies

In determining the CFC charge as set out in D4.435, a chargeable company is broadly one that has at least 25% of the total chargeable profits of the CFC apportioned to it by virtue of its relevant interest. This 25% includes any chargeable profits apportioned to relevant persons connected or associated with it at any time during the accounting period1.

Example

Two UK resident companies which are members of the same group, respectively have 90% and 10% of the CFC's chargeable profits apportioned to them. They are both chargeable companies.

The following are however excluded from the definition of a chargeable company:

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