INTM254800 - Controlled Foreign Companies: exemptions - Exempt Activities Test ('EAT'): Contents
This guidance applies for accounting period before 1 January 2013 and refers to the legislation at Chapter IV Part XVII of the Income and Corporation Taxes Acts 1988, under the old Controlled Foreign Companies (CFC) rules.
»Ê¹ÚÌåÓýapp current rules for CFCs are contained in Part 9A, Taxation (International and Other Provisions) Act 2010. This legislation is effective for accounting periods of CFCs beginning on or after 1 January 2013. »Ê¹ÚÌåÓýapp new guidance can be found at INTM190000 onwards.
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INTM254810»Ê¹ÚÌåÓýapp Exempt Activites Exemption
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INTM254820Territory of residence
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INTM254830Business establishment
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INTM254840Effectively managed in territory of residence
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INTM254850Further conditions
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INTM254860Main business
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INTM254870Investment business
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INTM254880Dealing in goods
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INTM254890Wholesale, distributive, financial or service business
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INTM254900Banking, deposit-taking, money-lending and debt factoring
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INTM254910Insurance companies
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INTM254920Companies holding shares and securities in subsidiaries
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INTM254930Business establishment and place of effective management
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INTM254940Definition of a holding company
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INTM254950Definition of a superior holding company
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INTM254960Income requirement of holding companies
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INTM254970Income requirement of superior holding companies
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INTM254980Qualifying exempt activity income
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INTM254990Ascertaining the source of income paid to a superior holding company
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INTM255000Computation of 'gross income'
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INTM255010Income treated as not derived from subsidiaries
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INTM255020Local holding companies
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INTM255030Exempt trading companies
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INTM255040Motive test, holding companies and superior holding companies
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INTM255050Example of a holding company structure