Related Commentary  Related HMRC Manuals

371BF(1)  A company (“C”) is not a chargeable company for the purposes of step 4 in section 371BC(1) if–

(a)the CFC is an offshore fund (as defined in section 355),

(b)at the relevant time and at all subsequent relevant times, C reasonably believes that the requirement of section 371BD(1) will not be met in relation to it, and

(c)the meeting of that requirement in relation to C is in no way attributable to any step–

(i)which was taken by C or any person connected or associated with C, and

(ii)which, at the time it was taken, could reasonably have been expected to cause that requirement to be met.

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