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

Section 371CE: meaning of "group treasury company"

Section 371CEA defines what a "group treasury company" means for the purposes of determining whether the Chapter 6 CFC charge gateway applies to a controlled foreign company.

• A CFC qualifies as a group treasury company if it is a member of a worldwide group, substantially all of its activities are treasury activities for the group, substantially all of its assets and liabilities relate to those activities, and at least 90% of its relevant income is group treasury revenue.
• Treasury activities include managing surplus cash or overdrafts, making or receiving deposits, lending money, holding shares in qualifying UK group treasury companies, investing in debt securities, and hedging assets, liabilities, income or expenses — all carried out for the group or its members.
• Group treasury revenue is the gross revenue (before any deductions) arising from treasury activities and accounted for as such under generally accepted accounting practice, but dividends or distributions only count if they come from a UK group company that itself meets the treasury company criteria.
• Relevant income means all gross income of the company arising from its activities and accounted for under generally accepted accounting practice before any deductions — the 90% test compares group treasury revenue against this total.