Where a company (C) holds a relevant interest in a CFC as a trading asset, the chargeable profits and creditable tax apportioned to C in respect of that relevant interest is to be left out of account in making the CFC charge at step 5 at ¶767-600 (TIOPA 2010, s. 371BG(2) and (3)).

A company (C) holds a relevant interest in a CFC as a trading asset where the following conditions are satisfied:

(1)at all times during the CFC's accounting period, C has all or part of the relevant interest by virtue of holding shares (the ‘relevant shares’) in the CFC (directly or indirectly);

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