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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: Relevant Interests in a CFC: Relevant Interests of UK resident companies

A UK resident company’s interest in a CFC will always be taken to be a relevant interest in a CFC with one exception. The exception to this will be where an indirect interest in that CFC is held by a UK resident company by virtue of it holding an interest in another UK resident company. This ensures that the relevant interest is held by the UK resident company that is at the bottom of a chain of two or more UK resident companies.