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

Introduction to Chapter

Section 371KA introduces the excluded territories exemption, which can prevent a controlled foreign company from being subject to the CFC charge.

• Chapter 11 establishes an exemption known as the "excluded territories exemption" (ETE)
• The ETE is one of the exemptions available under the CFC charge framework set out in section 371BA
• A list of qualifying excluded territories is specified by regulations made under powers conferred by this Chapter
• If a CFC meets the conditions of the ETE, including being resident and carrying on business in a listed territory, it is excluded from the CFC charge