»Ê¹ÚÌåÓýapp

In order to determine whether a person has a relevant interest in a CFC it must first be determined whether they have any interest at all. Whether a person has an interest in a CFC is determined by application of TIOPA10/S371VH. For detail on this see INTM248500.

TIOPA10/S371OA determines whether an interest held, following application of TIOPA10/S371VH, is a relevant interest. »Ê¹ÚÌåÓýappre are a number of rules to determine whether a person has a “relevant interestâ€� in the CFC concerned for the accounting period of the CFC. »Ê¹ÚÌåÓýapp rule(s) to be applied will depend on the residence and nature of the entity and its relationship to others who may also potentially have a relevant interest in the CFC.

Direct and indirect interests

In considering whether a person has a relevant interest it will also be necessary to consider whether the interest held is “direct� or “indirect�. An indirect interest in a CFC exists where a person has an interest by virtue of having an interest in another company. It follows that a person who has an interest in a CFC other than through another company has a direct interest in that CFC.