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HMRC internal manual

International Manual

Controlled Foreign Companies: exemptions - excluded countries: The excluded countries’ exemption

ICTA88/S748(1)(e), ICTA88/S748(1A) and SI1998/3081

Where a controlled foreign company is resident in a territory (INTM254490) listed in the excluded countries’ regulations - see SI1998/3081 - and satisfies particular requirements in respect of its income or gains no apportionment falls to be made for that accounting period. The territories on the list as well as entries for those territories on Part II will be revised at intervals. Proposed country changes will be announced by Press Release and will only have effect for controlled foreign companies’ accounting periods beginning on or after the date of the Press Release.

It is recognised that there may be occasions where information about the Controlled Foreign Company may not be available or the time it would take to verify beyond any doubt that the Controlled Foreign Company satisfies all of the conditions for the exemption would be disproportionate. In these circumstances, see INTM256620 for further guidance.

See INTM254580 for the current list of excluded countries.