Taxation (International and Other Provisions) Act 2010 section 371BD

Chargeable companies

Section 371BD defines which UK-resident companies are "chargeable companies" for the purposes of the CFC charge, based on a 25% ownership threshold.

  • A UK-resident company is a chargeable company if it meets the 25% test described below.
  • The test looks at the percentage of the CFC's chargeable profits apportioned to the company, plus the percentages apportioned to any connected or associated persons.
  • If those combined percentages total at least 25%, the company is a chargeable company and will be subject to the CFC charge.
  • Special rules apply for companies that are managers of, or participants in, offshore funds.

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