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HMRC internal manual

International Manual

Controlled Foreign Companies: Entity Exemptions: Chapter 14 - The Tax Exemption: contents

The purpose of this entity level exemption is to easily exclude a CFC from having to apply the CFC rules to its profits when it pays a normal to high level of tax in its territory of residence.

Any CFC that satisfies the tax exemption, does not need to be included in a chargeable company’s corporation tax return.