Section GB 15C — Income Tax Act 2007: Arrangements related to accounting test for non-attributing active CFC

GB 15C Arrangements related to accounting test for non-attributing active CFC When this section applies (1) This section applies when a person (the party ) enters an arrangement having a purpose, that is more than incidental, of enabling a CFC to meet the requirements of section EX 21E (Non-attributing active CFC: test based on accounting standard) when the CFC would not meet the requirements of section EX 21D (Non-attributing active CFC: default test) to be a non-attributing active CFC. CFC not non-attributing active CFC (2) The CFC is not a non-attributing active CFC. Person not non-attributing active CFC if type of financial arrangement involved (3) A party who is a CFC associated with the CFC is not a non-attributing active CFC if— (a) the arrangement involves a financial arrangement producing a foreign exchange loss for the CFC; and (b) the foreign exchange loss decreases for the CFC the amount of the numerator in the formula in section EX 21E(5) . Defined in this Act: arrangement , associated , CFC , financial arrangement , loss , non-attributing active CFC Section GB 15C: inserted (with effect on 30 June 2009), on 6 October 2009, by section 237(1) of the Taxation (International Taxation, Life Insurance, and Remedial Matters) Act 2009 (2009 No 34).