INTM224270 - Controlled Foreign companies: Entity Exemptions: Chapter 10 - The Exempt Period Exemption: Chargeable company condition
The chargeable company condition is met if the 바카라 사이트渃harging condition바카라 사이트� in TIOPA10/S371JC is met and throughout the 바카라 사이트渞elevant period바카라 사이트� either a company which has a relevant interest in the CFC at the beginning of the exempt period is an 바카라 사이트渙riginal chargeable company바카라 사이트� or is connected with an original chargeable company. The effect of this is that the availability of the exempt period exemption is not affected by a transfer of ownership of a CFC within a group if there is at least one connected UK company which could be subject to a CFC charge in respect of the new CFC rules.
The 바카라 사이트渞elevant period바카라 사이트� is the period from immediately after the beginning of the exempt period until the end of the subsequent period (i.e. the end of the first accounting period beginning after the end of the exempt period).
An 바카라 사이트渙riginal chargeable company바카라 사이트� is a company which would be a chargeable company at the start of the exempt period for the purposes of the charging condition set out in TIOPA10/S371JC.