INTM248350 - Controlled Foreign Companies: Definitions for terms in Part 9A: Alphabetic index of terms defined in Part 9A: Connected persons

TIOPA10/S371VF sets out the rules for identifying connected persons. This includes persons who are 바카라 사이트śassociated바카라 사이트ť or 바카라 사이트śconnected바카라 사이트ť to the CFC in question, as those terms are defined in and respectively.

The section provides that a person will be related to a CFC if any of the three following circumstances exists:

  1. the person is associated or connected with the CFC;
  2. if there were to be a CFC charge, at least 25% of the CFC바카라 사이트™s chargeable profits would be apportioned to the person; or
  3. if the CFC is a CFC by virtue of TIOPA10/S371RC (see INTM236200), the person is connected or associated with either or both of the controllers.