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HMRC internal manual

International Manual

Controlled Foreign Companies: The CFC charge gateway chapter 8 - solo consolidation

This chapter contains the rules that identify the profit that is within the scope of the CFC charge because the CFC is the subject of a solo consolidation waiver, or because there are arrangements that have broadly equivalent regulatory effect.

Chapter 8 applies only to CFCs that are controlled by UK resident persons carrying on banking business as defined in TIOPA10/Part 9A/S371VA (see INTM248100).