Controlled Foreign Companies: exemptions - Exempt Activities Test ('EAT'): Exempt trading companies
A company is an exempt trading company if it is a trading company throughout each of its accounting periods which falls wholly or partly within the accounting period of the holding company under consideration and is:-
- not subject to a lower level of taxation, or
- is resident in a territory specified in the excluded countries regulations and satisfies the condition regarding income or gains, or
- satisfies the motive test.