CFCs

Question 1

Conditions (2)

Answer 1

• Uk company owns >25% of interest

- Controlled in the UK

Question 2

Exemptions (5)

Answer 2

• Exempt for first 12 months of being a CFC
• CFC is in excluded territory
• CFC’s profits are 75% of UK CT

Question 3

Calculation of UK CT payable

Answer 3

UK’s % of CFC profits
Less: DTR
Less: UK CT already paid by CFC
= CFC charge