Where the relevant interests in a CFC are not held solely by virtue of ordinary shares then the formulaic approach will not apply and instead TIOPA10/S371QC(2) applies to require an apportionment of the chargeable profits and creditable tax for the relevant accounting period on a just and reasonable basis among the persons who have relevant interests in the CFC at any time in that period.

For a basis to be just and reasonable, it should reflect the power the relevant person has to secure that the income of the CFC is applied for their benefit. In doing so the following general principles should be followed:

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