Commentary

D4.460 Summary of CFC rules prior to 1 January 2013

Corporate tax
Corporate tax | Commentary

D4.460 Summary of CFC rules prior to 1 January 2013

Corporate tax | Commentary

CFCs prior to 1 January 2013

D4.460 Summary of CFC rules prior to 1 January 2013

For CFC accounting periods beginning on or after 1 January 2013, a different CFC regime applies. For details see D4.401.

Prior to 1 January 2013, the general rule was that if a company was a CFC for an accounting period, and was not within any of the statutory exemptions, its chargeable profits for that accounting period (which did not include capital gains) were apportioned among all the persons who had a relevant interest in the CFC at any time in that period. Where 25%

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