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HMRC internal manual

International Manual

Controlled Foreign Companies: Entity Exemptions: Chapter 11 - The Excluded Territories Exemption: The extra condition

Regulation 5 and Part 2 of the Schedule to the Controlled Foreign Companies (Excluded Territories) Regulations 2012 SI 3024 provide that an extra condition must be met for the excluded territories exemption to apply if the CFC carries on insurance business. The extra condition is that none of the insurance business of the CFC is carried on in Luxembourg.