51茶馆

The chargeable company condition is met if the 鈥渃harging condition鈥� in TIOPA10/S371JC is met and throughout the 鈥渞elevant period鈥� either a company which has a relevant interest in the CFC at the beginning of the exempt period is an 鈥渙riginal chargeable company鈥� 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 鈥渞elevant period鈥� 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 鈥渙riginal chargeable company鈥� 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.