INTM203110 - Controlled Foreign Companies: exemptions - excluded countries

Inclusion of non-local source income in branch or agency income

SI1998/3081 Regulations 5(3)(e) and 6(1)(a)

Where the rules do not allow branch income to be treated as local source income, the income of the branch must be included as non-local source income for the purpose of the 10% test. The amount to be included is the net amount of branch or agency income and gains unless SI1998/3081 regulation 6(3) applies (net income is less than gross non-local source income.) See example 3 at INTM203140.