Section 371KC | How to determine the territory in which a CFC is resident ^F1

(1)For the purposes of this Chapter the territory in which a CFC is resident for an accounting period is to be determined in accordance with this section; and in this Chapter “the CFC's territory” means that territory as so determined.

(2)The CFC is taken to be resident in the territory determined in accordance with section 371TA.

(3)But section 371TA(1)(b) is to be applied only if, at all times during the accounting period, the CFC or persons with interests in the CFC are liable under the law of the territory in question to tax on the CFC's income.

(4)If, as a result of subsection (3), no territory of residence can be determined, the excluded territories exemption cannot apply for the accounting period.