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International Manual

Controlled Foreign Companies: Definitions for terms in Part 9A: Alphabetic index of terms defined in Part 9A: Connected persons

TIOPA10/S371VF sets out the rules for identifying connected persons. This includes persons who are “associated” or “connected” to the CFC in question, as those terms are defined in CTA10/S882(2)-(7)(web) and CTA10/S1122 (Web) respectively.

The section provides that a person will be related to a CFC if any of the three following circumstances exists:

  1. the person is associated or connected with the CFC;
  2. if there were to be a CFC charge, at least 25% of the CFC’s chargeable profits would be apportioned to the person; or 
  3. if the CFC is a CFC by virtue of TIOPA10/S371RC (see INTM236200), the person is connected or associated with either or both of the controllers.