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

Does Chapter 8 apply?

Section 371CG determines when the solo consolidation rules in Chapter 8 apply to a controlled foreign company's accounting period.

• Chapter 8 (solo consolidation) only applies to a CFC's accounting period if one of two specific conditions is met
• Condition A applies where the CFC is subject to a solo consolidation waiver under the PRA Handbook and its parent undertaking for that waiver is a UK resident company
• Condition B applies where a UK resident bank controls the CFC, holds shares in it whose fall in value would be largely ignored for regulatory capital purposes, and a main purpose of holding those shares is to obtain a tax advantage
• The Treasury has power to amend these rules by regulations to reflect changes to the PRA Handbook or related regulatory publications