The total of a CFC's income across four categories is to be considered against a threshold in determining if the excluded territories exemption applies for a period (see ¶769-740). These four categories of income are considered below. Note that for this purpose income which falls within more than one category is to be counted once (TIOPA 2010, s. 371KB(4)).
Category A income
Category A is intended to catch income which is exempt from tax, is taxed at a reduced rate or is taxed in such a manner that part or all of the tax is repayable, in the CFC's territory of residence.