INTM224325 - Controlled Foreign companies: Entity Exemptions: Chapter 10 - »Ê¹ÚÌåÓýapp Exempt Period Exemption: Extension to the exempt period granted
Where a CFC has claimed, and been granted by HMRC, an extension to the normal 12 month exempt period the same approach applies as for a 12 month exempt period, recognising that the profits relating to the whole of an extended exempt period are potentially exempt. »Ê¹ÚÌåÓýapp amount of potentially exempt chargeable profits must be calculated by apportioning profits from any accounting period which falls partly within the extended exempt period.
»Ê¹ÚÌåÓýapp period by which the subsequent period condition is to be tested remains the first full accounting period immediately following the end of the exempt period.
Example
A CFC’s exempt period begins on 1 July 2013. »Ê¹ÚÌåÓýapp CFC’s accounting periods run from 1 July to 30 June (12 month periods). »Ê¹ÚÌåÓýapp exempt period would be 1 July 2013 to 30 June 2014.
This is subject to the subsequent period condition being met, and the subsequent period would be the accounting period 1 July 2014 to 30 June 2015.
However, the group applies for, and HMRC agrees to, an extended exempt period of 18 months. »Ê¹ÚÌåÓýapp Exempt period now becomes 1 July 2013 to 31 December 2014.
This is still subject to the subsequent period condition being met. »Ê¹ÚÌåÓýapp subsequent period is the first accounting period which ends after the end of the (extended) exempt period. »Ê¹ÚÌåÓýapp subsequent period is now 1 July 2015 to 30 June 2016.