background image
13.3. CFC and Similar Regimes

A Controlled Foreign Company (CFC) or Controlled Foreign Trust (CFT) means a non-resident company or trust in which a resident person holds 50% of ownership interest (subject to certain other conditions), whether directly or indirectly, through one or more interposed non-resident entities, and where the person is associated with such company or trust.

Resident person is taxed on the undistributed income of CFC and CFT which is deemed to be received by the resident person.