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HMRC internal manual

International Manual

Controlled Foreign Companies: exemptions - Exempt Activities Test ('EAT'): Territory of residence


It is necessary for the purposes of the exempt activities test to establish a single territory of residence for a controlled foreign company. In most cases the territory of residence will have been determined for the purposes of the lower level of taxation test under ICTA88/S749. However where a controlled foreign company has no territory of residence special rules apply.

See INTM254400.