INTM432150 - TIOPA10 Part 4: how it works - Interaction with CFC legislation

A provision between a UK company and any associated controlled foreign company ('CFC') will of course be subject to TIOPA10/Part 4. However when calculating the profits of the CFC, the CFC legislation requires the computation to be made as if the company were UK resident. This means that the computation has to take account of TIOPA10/Part 4.

Guidance on the interaction can be found from INTM209050.