Taxes Consolidation Act 1997 section 835L

Application of Part to a controlled foreign company

Section 835L applies the controlled foreign company (CFC) rules contained in this Part for any accounting period in which a company is regarded as a CFC.

• The CFC provisions apply on an accounting period by accounting period basis, so a company must be tested for CFC status in each period.
• Where a company is a CFC in a given accounting period, the full provisions of this Part apply to that period.
• The section includes a general saving: the provisions apply "except as otherwise provided for in this Part", meaning specific exemptions or exclusions elsewhere in this Part take precedence.
• The section was introduced by Finance Act 2018 as part of Ireland's implementation of the EU Anti-Tax Avoidance Directive (ATAD) CFC rules.