http://www.legislation.gov.uk/ukpga/2010/8/section/371TCTaxation (International and Other Provisions) Act 2010An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite Acts; and for connected purposes.texttext/xmlenStatute Law Database2025-04-29Expert Participation2025-03-20 PART 9AChapter 20371TC1An election under section 371TB(8)—amay be made only by a company or companies determined under subsection (2) or (3),bmust be made by notice to an officer of Revenue and Customs,cmust be made no later than 12 months after the end of the relevant accounting period,dmust state, in relation to each company making the election, the percentage of the CFC's chargeable profits for the relevant accounting period which would be likely to be apportioned to the company at step 3 in section 371BC(1) were section 371BC (charging the CFC charge) to apply in relation to the relevant accounting period,emust be signed on behalf of each company making the election, andfis irrevocable.2A company may make an election if it is likely that, were section 371BC (charging the CFC charge) to apply in relation to the relevant accounting period, the company would be a chargeable company whose apportioned percentage of the CFC's chargeable profits for the relevant accounting period would represent more than half of X%.3Two or more companies may together make an election if it is likely that, were section 371BC (charging the CFC charge) to apply in relation to the relevant accounting period, the companies would all be chargeable companies whose apportioned percentage of the CFC's chargeable profits for the relevant accounting period would, taken together, represent more than half of X%.4In subsections (2) and (3) “X%” means the total percentage of the CFC's chargeable profits for the relevant accounting period which would be likely to be apportioned to chargeable companies were section 371BC (charging the CFC charge) to apply in relation to the relevant accounting period.5In subsections (2) to (4) references to apportioned percentages of the CFC's chargeable profits for the relevant accounting period are to the percentages apportioned at step 3 in section 371BC(1).6A designation under section 371TB(9) is irrevocable.7An officer of Revenue and Customs must give notice of a designation to each company which the officer considers would be likely to be a chargeable company were the CFC charge to be charged in relation to the relevant accounting period.8The notice must specify—athe date on which the designation was made,bthe CFC's name,cthe relevant accounting period, anddthe territory designated.9An election or designation has effect in relation to—athe relevant accounting period, andbeach successive accounting period of the CFC until subsection (10) applies to an accounting period,regardless of any change in the persons who have interests in the CFC or any change in those interests.10This subsection applies to an accounting period (“the later period”) if—aone or more of the territories which were eligible territories in relation to the relevant accounting period does not fall within section 371TB(1) in relation to the later period, orbsome other territory also falls within section 371TB(1) in relation to the later period.Pt. 9A inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1 (with ss. 56-58)