835K Accounting periods

Summary

This section sets out the rules for determining the accounting period of a CFC.

Details

(1) A CFC’’s accounting period begins on the date it becomes a CFC, and where it continues to be a CFC, a new accounting period begins immediately after the end of the previous accounting period.

Relevant subsections of section 27 of the TCA apply in determining accounting periods.

(2) A CFC’’s accounting period ends when the company ceases to be a CFC, when the CFC becomes or ceases to be resident in a territory and when the company ceases to have any sources of income.

(3) Subject to subsections (1) and (2) of this section, subsections (3), (5) and (7) of section 27 of the TCA, which broadly provide for when an accounting period shall be deemed to have ended, apply in determining accounting periods.

(4) Where the beginning or end of a CFC’’s accounting period is uncertain, a Revenue officer may determine the accounting period, for a period of no more than 12 months, until further facts are available.

(5) Revenue shall issue a notice in writing to the controlling company of any determination made in accordance with subsection (4).

A controlling company can appeal any determination made by Revenue under subsection (5) within 30 days of the notice issuing.

Relevant Date: Finance Act 2021