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HMRC internal manual

International Manual

Controlled Foreign Companies: legislation - introduction and outline: Statutory Exclusions

There are a number of statutory exclusions designed to target the Chapter IV charge more specifically.

An overseas company will not necessarily be a controlled foreign company in each of its accounting periods and a controlled foreign company may meet the requirements of an exclusion in one accounting period even if it fails to do so in another. In practice most overseas companies which are under United Kingdom control will not be subject to a charge under Chapter IV.

The remaining pages in this chapter contain a general introduction to the scope of the legislation and direct the reader to more detailed information on particular aspects.