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HMRC internal manual

International Manual

Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D: Condition D

Condition D (TIOPA10/S371CA(11))

Condition D is met if the CFC’s assumed total profits only consist of one or both of:

  • non-trading finance profits;
  • property business profits.

Any such profits are excluded from the CFC’s assumed total profits for the purposes of Chapter 4. Non-trading finance profits are dealt with in Chapter 5 and property business income is outside the scope of the CFC charge. Chapter 4 will not apply where a CFC has no profits of any other kind but these.