A number of terms are used frequently in the CFC rules (TIOPA 2010, Pt. 9A). Some of these are considered below.

Meaning of ‘related’

A person is ‘related’ to a CFC if:

the person is connected or associated with the CFC;

at least 25 per cent of the CFC's chargeable profits would be apportioned to the person in applying the CFC charge if it was necessary to apply that charge; or

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