It is necessary to firstly establish in what situations this gateway test applies and then if it does, the extent to which profits pass through the gateway. Only profits which pass through the gateway are potentially liable to the CFC charge.
Establishing whether the test applies
Chapter 3 sets out the queries to be answered in ascertaining whether the Chapter 7 gateway applies. This gateway test applies if at any time during the accounting period, the main part of the CFCs business is insurance business and the CFCs assumed total profits (see D4.421) include amounts which derive from insurance contracts entered into with1:
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