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

Connected persons etc.

Section 371VF defines who counts as "connected", "associated" and "related" to a controlled foreign company (CFC) for the purposes of the CFC rules in Part 9A.

• The standard Corporation Tax Act 2010 definitions of "associated" persons (section 882(2) to (7)) and "connected" persons (section 1122) apply throughout the CFC rules.
• A person is "related" to a CFC if they are connected or associated with it under those standard definitions.
• A person is also "related" to a CFC if at least 25% of the CFC's chargeable profits would be apportioned to them were a CFC charge to arise for the accounting period in question.
• Where a CFC is controlled under the 40% joint-control rule (section 371RC), a person is "related" to the CFC if they are connected or associated with either or both of the controllers.