835 Low accounting profit exemption

Summary

This section excludes from the scope of the CFC rules a CFC with accounting profits of less than €€750,000 where any non-trading income stream amounts to less than €€75,000, or, a CFC with accounting profits of less than €€75,000.

Details

(1) A CFC with:

• accounting profits of less than €€750,000 where the non-trading income amounts to less than €€75,000, or,
• a CFC with accounting profits of less than €€75,000,

is exempt from a CFC charge.

(2) Where the accounting period is less than 12 months, the amounts specified should be proportionately reduced.

(3) & (4) As an anti-avoidance measure, the exemption shall not apply where the CFC enters into arrangements, the main purpose of which is to ensure that the low accounting profit exemption applies. Similarly, the amounts specified should be proportionately reduced where the accounting period is less than 12 months.

Relevant Date: Finance Act 2021