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Official guidance
International Manual

INTM197300 · Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D

  • INTM197310 · Condition A
  • INTM197320 · Condition B
  • INTM197330 · Condition C
  • INTM197340 · Condition D
  • INTM197360 · Example 1
  • INTM197370 · Example 2
  • INTM197380 · Example 3
  • INTM197390 · Example 4
  • INTM197400 · Example 5
  • INTM197350 · Flowcharts
  1. Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D: contents
  2. Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D: Condition D

INTM197340 | Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D: Condition D

From HM Revenue & Customs · International Manual

Condition D (TIOPA10/S371CA(11))

Condition D is met if the CFC’s assumed total profits only consist of one or both of:

  • non-trading finance profits;

  • property business profits.

Any such profits are excluded from the CFC’s assumed total profits for the purposes of Chapter 4. Non-trading finance profits are dealt with in Chapter 5 and property business income is outside the scope of the CFC charge. Chapter 4 will not apply where a CFC has no profits of any other kind but these.

For visual illustration view diagram showing Condition D decision flowchart

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