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HMRC internal manual

International Manual

Controlled Foreign Companies: exemptions - the motive test: The diversion of profits leg of the motive test: are there receipts reflected in the controlled foreign company’s profits for an accounting period?

We start off with a relatively straightforward question to which the answer will almost certainly be yes since (with the possible exception of a company whose profits were wholly made up of increases in the value of its assets) it would be exceptionally rare for there to be no receipts reflected in the profits of the controlled foreign company.