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Home / Simons-Taxes /Corporate tax /Part D4 Overseas issues /Division D4.4 Controlled foreign companies (CFCs) /Full exemptions from CFC regime / D4.414 CFCs—low profit margin exemption
Commentary

D4.414 CFCs—low profit margin exemption

Corporate tax

A company is exempt from the CFC charge if the CFC's accounting profits are no more than 10% of its relevant operating expenditure. Any CFC that satisfies the low profit margin exemption, does not need to be included in a chargeable company's corporation tax return.

Accounting profits are profits further adjusted to be determined before the deduction

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