INTM207000 - Controlled Foreign Companies: exemptions - de minimis

The de minimis exemption

ICTA88/S748(1)(d)

Under ICTA88/S748(1)(d) no apportionment is due in respect of an accounting period of a controlled foreign company in which its chargeable profits do not exceed £50,000. If the accounting period is less than twelve months the amount of £50,000 is proportionally reduced. An apportionment will be due, if none of the exemptions applies, regardless of however small the amount by which the de minimis limit is exceeded.