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

Overview of Chapter

Section 371RA provides an overview of the chapter dealing with how "control" of a company is determined for the purposes of the controlled foreign companies (CFC) rules.

• The chapter sets out how to determine whether a company is "controlled" by another person or persons for the purposes of the CFC regime.
• Control is assessed under two main approaches: legal and economic control (section 371RB) and control determined by reference to accounting standards (section 371RE).
• Additional provisions (sections 371RC and 371RG) identify cases where a non-UK resident company that would not normally qualify as a CFC is nevertheless treated as one.
• These extended CFC treatment rules capture companies that fall outside the standard control tests but where sufficient UK interest or involvement exists.