INTM227200 - Controlled Foreign Companies: Relevant Interests in a CFC: Whether a person has a Relevant Interest
In order to determine whether a person has a relevant interest in a CFC it must first be determined whether they have any interest at all. Whether a person has an interest in a CFC is determined by application of TIOPA10/S371VH. For detail on this see INTM248500.
TIOPA10/S371OA determines whether an interest held, following application of TIOPA10/S371VH, is a relevant interest. There are a number of rules to determine whether a person has a 바카라 사이트渞elevant interest바카라 사이트� in the CFC concerned for the accounting period of the CFC. The rule(s) to be applied will depend on the residence and nature of the entity and its relationship to others who may also potentially have a relevant interest in the CFC.
Direct and indirect interests
In considering whether a person has a relevant interest it will also be necessary to consider whether the interest held is 바카라 사이트渄irect바카라 사이트� or 바카라 사이트渋ndirect바카라 사이트�. An indirect interest in a CFC exists where a person has an interest by virtue of having an interest in another company. It follows that a person who has an interest in a CFC other than through another company has a direct interest in that CFC.