Section 371BC of TIOPA 2010 provides the following method for making a CFC charge.

Step 1: Determine the persons (the ‘relevant persons’) who have relevant interests in the CFC at any time during the accounting period (see ¶769-880 for commentary on how to determine if a person has a relevant interest in the CFC). If one or more of those persons is a company which satisfies the UK residence condition (i.e. it was UK-resident at a time during the period when it had a relevant interest in the CFC), go to step 2. If this is not the case, no further steps are to be taken and the CFC charge is not applied.

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