TIOPA10/Part 9A/S371SD provides that the CFC is assumed to be resident in the UK from the beginning of the CFC's first accounting period in which it becomes subject to Part 9A (i.e. its first accounting period beginning on or after 1 January 2013) until the company ceases to be a CFC. It is also assumed that the CFC is, has been and will continue to be within the charge to UK corporation tax, and that its accounting periods are accounting periods for corporation tax purposes.

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