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HMRC internal manual

International Manual

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HM Revenue & Customs
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Controlled Foreign Companies: Entity Exemptions: Chapter 10 - The Exempt Period Exemption: contents

The Exemption Period Exemption provides an entity-level exemption for CFCs that have come under UK control for the first time. The period of exemption is temporary, usually 12 months.

A chargeable company has to list any CFCs relying on this exemption on its corporation tax return