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Home / Simons-Taxes /Corporate tax /Part D4 Overseas issues /Division D4.4 Controlled foreign companies (CFCs) /Scope of CFC provisions / D4.404 Definition of control for CFC purposes
Commentary

D4.404 Definition of control for CFC purposes

Corporate tax

In broad terms, a company will be 'controlled' by any person or persons who (directly or indirectly) have 'legal' control or 'economic' control of the company, or who have control of the company by reference to accounting standards. Special rules (outlined below) apply to banks, international joint venture companies, and cell companies.

Legal control of CFCs

A person controls a company if they have the power to secure that the affairs of the company are conducted in accordance with their wishes either1:

  1. Ìý

    •ÌýÌýÌýÌý by means of the holding of shares or the possession of voting power in that or any other company, or

  2. Ìý

    •ÌýÌýÌýÌý by virtue of any powers conferred by the articles of association or other document regulating that company or any other company

The scope of documents falling within the second bullet point above is not limited to documentation required by local law in the country of incorporation of the CFC. A shareholders' agreement, for example, could have the effect of conferring legal control of a company

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Web page updated on 17 Mar 2025 17:13