Controlled Foreign Companies: Entity Exemptions: Chapter 13 - The Low Profit Margin Exemption: Anti-avoidance
TIOPA10/S371MC provides an anti-avoidance rule to prevent the exemption from applying where an arrangement is entered into which has a main purpose of securing that the exemption applies. The arrangement can have been entered into at any time.
“Arrangement” is widely defined. Further details of what is meant by an arrangement can be found at INTM248100.