The excluded territories exemption aims to exempt those CFCs that pose a low risk to the UK corporate tax base by artificial diversion of UK profits, due to their territory of residence or the type of income that they receive.
A CFC will be excluded from the CFC charge if1:
- Ìý
•ÌýÌýÌýÌý the company is resident and carries on business in an excluded territory as specified in SI 2012/3024
- Ìý
•ÌýÌýÌýÌý the total of the CFCs relevant income (Categories A-D, see below) does not exceed the 'threshold amount' of 10% of the CFC's accounting profits excluding transfer pricing adjustments for the accounting period in question, or £50,000 if greater (reduced proportionately if the accounting period is less than 12 months) 2
- Ìý
•ÌýÌýÌýÌý the IP condition is met (see below), and
- Ìý
•
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Web page updated on 24 Aug 2024 14:47