Section 371QC | The basic rules

(1)If conditions X to Z are met, the CFC's chargeable profits and creditable tax are to be apportioned among the relevant persons in accordance with section 371QD.

(2)If not, the percentage of the chargeable profits and the percentage of the creditable tax to be apportioned to each relevant person is to be determined on a just and reasonable basis.

(3)Condition X is that the relevant persons all have their relevant interests by virtue only of their holding, directly or indirectly, ordinary shares in the CFC.

(4)Condition Y is that each relevant person meets the requirement that the person is either—

(a)UK resident at all times during the accounting period, or

(b)non-UK resident at all times during the accounting period.

(5)Condition Z is that no company which has an intermediate interest in the CFC at any time in the accounting period has that interest otherwise than by virtue of holding, directly or indirectly, ordinary shares in the CFC.

(6)A company (“C”) has an “intermediate interest” in the CFC if—

(a)C has an interest in the CFC, and

(b)one or more of the relevant persons have relevant interests in the CFC by virtue of having an interest in C.