INTM254800 - Controlled Foreign Companies: exemptions - Exempt Activities Test ('EAT'): Contents

This guidance applies for accounting period before 1 January 2013 and refers to the legislation at Chapter IV Part XVII of the Income and Corporation Taxes Acts 1988, under the old Controlled Foreign Companies (CFC) rules.

The current rules for CFCs are contained in Part 9A, Taxation (International and Other Provisions) Act 2010. This legislation is effective for accounting periods of CFCs beginning on or after 1 January 2013. The new guidance can be found at INTM190000 onwards.

1. INTM254810

   The Exempt Activites Exemption
2. INTM254820

   Territory of residence
3. INTM254830

   Business establishment
4. INTM254840

   Effectively managed in territory of residence
5. INTM254850

   Further conditions
6. INTM254860

   Main business
7. INTM254870

   Investment business
8. INTM254880

   Dealing in goods
9. INTM254890

   Wholesale, distributive, financial or service business
10. INTM254900

    Banking, deposit-taking, money-lending and debt factoring
11. INTM254910

    Insurance companies
12. INTM254920

    Companies holding shares and securities in subsidiaries
13. INTM254930

    Business establishment and place of effective management
14. INTM254940

    Definition of a holding company
15. INTM254950

    Definition of a superior holding company
16. INTM254960

    Income requirement of holding companies
17. INTM254970

    Income requirement of superior holding companies
18. INTM254980

    Qualifying exempt activity income
19. INTM254990

    Ascertaining the source of income paid to a superior holding company
20. INTM255000

    Computation of 'gross income'
21. INTM255010

    Income treated as not derived from subsidiaries
22. INTM255020

    Local holding companies
23. INTM255030

    Exempt trading companies
24. INTM255040

    Motive test, holding companies and superior holding companies
25. INTM255050

    Example of a holding company structure