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

Application of Chapter

Section 371OA introduces the rules for determining which persons hold a "relevant interest" in a controlled foreign company (CFC), which is a key step in working out who is liable to a CFC charge.

• Chapter 15 sets out how to identify persons who have a "relevant interest" in a CFC, as required by the CFC charging mechanism in section 371BC(1)
• The relevant interest rules determine both which UK persons have an interest in a CFC and the size of that interest
• A CFC's chargeable profits are shared out among relevant interest holders, provided they are UK resident companies holding a sufficient proportion of the total interest in the CFC
• Not every person with an interest in a CFC necessarily holds a relevant interest — only direct shareholders, not indirect holders through another UK company, will typically qualify